Under international Tax Treaties if an individual is deemed to be a resident of both Contracting States, a series of tie-breaker rules are provided to determine a single State of residence for that individual whereas the first test is based on where the individual has a permanent home. If that test is inconclusive he will be considered to be a resident of the Contracting State where his personal and economic relations are closest (i.e., the location of his "center of vital interests")
(1) Do you know of any court or tax rulings (EU or other) supporting the claim that a place of residence is regarded as "a permanent home" even if the individual resided in such a home for a period of 1.5 years only? (taken an initial strong intention of a 5 year stay - supported by a 5 years work contract that was unfortunately revoked after 1.5 years)
(2) The same supporting the claim that the "center of vital interests" will determine tax residency even if such center persisted for a period of 1.5 years only?