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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>DTAA Article 4: Residency Defined for Individuals and Entities; Mutual Agreement Needed for Dual Residency Resolution</h1> Article 4 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States defines 'resident' as any person liable to tax in a State due to domicile, residence, or similar criteria. If an individual is considered a resident in both States, residency is determined by permanent home, center of vital interests, habitual abode, or nationality. If unresolved, competent authorities decide by mutual agreement. For entities, the place of effective management initially determined residency, but now mutual agreement between authorities is required. Without agreement, entities receive no tax relief except as agreed by authorities.
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