Resident status under DTAA: rules for determining tax residence and tie breaker criteria for individuals and entities. Definition of resident for the DTAA: liable to tax under domestic criteria such as domicile, residence, place of management or registration; excludes persons taxable only on domestic source income or capital. For individuals with dual residency, residence is resolved by permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement. For non individuals with dual residency, residence is determined by place of effective management, or otherwise by mutual agreement between competent authorities.
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Provisions expressly mentioned in the judgment/order text.
Resident status under DTAA: rules for determining tax residence and tie breaker criteria for individuals and entities.
Definition of resident for the DTAA: liable to tax under domestic criteria such as domicile, residence, place of management or registration; excludes persons taxable only on domestic source income or capital. For individuals with dual residency, residence is resolved by permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement. For non individuals with dual residency, residence is determined by place of effective management, or otherwise by mutual agreement between competent authorities.
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