Introducing the “In Favour Of” filter in Case Laws.
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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' and Resolves Dual Residency with Permanent Home, Vital Interests, or Nationality.</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, place of management, or incorporation. If an individual qualifies as a resident in both states, residency is determined by the location of their permanent home, center of vital interests, habitual abode, or nationality. For entities, residency disputes are resolved by mutual agreement based on incorporation and management location. Without agreement, the entity cannot claim benefits under the Agreement.
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