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of <h1>Article 4: Defines 'Resident' for Double Taxation Avoidance, Addresses Dual Residency with Permanent Home and Economic Ties.</h1> Article 4 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States defines a 'resident' as any person liable to tax in a State due to domicile, residence, or management location, excluding those taxed only on local income. For dual residency, individuals are deemed residents of the State with a permanent home or closer personal and economic relations. If unresolved, habitual abode or nationality is considered. For entities, residency is determined by mutual agreement based on effective management or incorporation location. Without agreement, no tax relief is granted unless mutually decided by the competent authorities.
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