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Introducing the βIn Favour Ofβ filter in Case Laws.
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<h1>Article 4 of DTAA Explains 'Resident' Definition and Dual Residency Resolution for Individuals and Entities</h1> Article 4 of the Double Tax Avoidance Agreement (DTAA) between Luxembourg and another Contracting State defines 'resident of a Contracting State' as any person subject to tax in that State due to domicile, residence, place of management, or similar criteria, excluding those taxed only on income from sources within the State. For individuals deemed residents of both States, residency is determined by permanent home, center of vital interests, habitual abode, or nationality. For entities, residency is based on the place of effective management. If residency cannot be determined, competent authorities will attempt to resolve it by mutual agreement.