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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 4 of DTAA Defines 'Resident' for Tax Purposes, Outlines Criteria for Dual Residency Resolution</h1> Article 4 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States defines a 'resident' as any person liable to tax in a State due to domicile, residence, incorporation, or management. If an individual qualifies as a resident in both States, residency is determined by permanent home, center of vital interests, habitual abode, or nationality. For non-individuals, residency is based on the place of effective management. If these criteria are inconclusive, the States' authorities will resolve the matter through mutual agreement. The provision aims to clarify tax liabilities and prevent double taxation.
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