Resident status determination defines who qualifies as resident and establishes tie breaker tests for dual residency under the treaty. Article 4 of the India-UAE tax treaty defines resident of a Contracting State: India treats as resident any person liable to tax by domicile, residence, ... Summary
Resident status determination defines who qualifies as resident and establishes tie breaker tests for dual residency under the treaty.
Article 4 of the India-UAE tax treaty defines resident of a Contracting State: India treats as resident any person liable to tax by domicile, residence, place of management or similar criteria (excluding those taxable only on India-source income); the UAE treats certain individuals and companies as residents based on presence and incorporation/management. The Article deems governments and specified institutions to be residents and recognizes Abu Dhabi Investment Authority as a UAE resident. Dual-resident individuals are subject to tie-breaker tests (permanent home, centre of vital interests, habitual abode, nationality), and dual-resident entities are resident where the place of effective management is located.
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