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Introducing the βIn Favour Ofβ filter in Case Laws.
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<h1>Article 4 of DTAA: Determining Residency for Tax Purposes Based on Domicile, Permanent Home, or Effective Management.</h1> Article 4 of the Double Tax Avoidance Agreement (DTAA) between Brazil and another Contracting State defines 'resident of a Contracting State' for tax purposes as any person liable to tax due to domicile, residence, or similar criteria. If an individual is considered a resident of both states, residency is determined by the location of a permanent home, center of vital interests, habitual abode, or nationality. If unresolved, authorities will mutually agree on residency. For entities, residency is determined by the location of effective management.