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of <h1>Understanding 'Resident' Status in Double Tax Avoidance Agreements: Key Criteria and Resolution Methods</h1> For the purposes of the Double Tax Avoidance Agreement (DTAA), a 'resident of a Contracting State' is defined as any person liable to tax in that state due to domicile, residence, place of management, or incorporation, excluding those taxed only on income from sources within the state. If an individual is deemed a resident of both states, residency is determined by permanent home, center of vital interests, habitual abode, or nationality. For entities, residency is resolved by mutual agreement between states, considering effective management and incorporation. Without agreement, the entity is not considered a resident of either state for treaty benefits.
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