MTT18050 | Scope: Determining location of entities: Meaning of 'tax resident' for individuals

From HM Revenue & Customs · Multinational Top-up Tax and Domestic Top-up Tax

An individual is considered to be tax resident for MTT purposes in any territory in which they are tax resident for the purposes of an income tax imposed by the same territory.

Example

According to the rules of an income tax imposed by Territory A, John is tax resident in Territory B.

This does not necessarily mean that John is tax resident in Territory B for MTT purposes. John will only be tax resident in Territory B for MTT purposes if Territory B itself imposes an income tax under which John is tax resident in that territory.