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of <h1>Clarification of 'Resident' in Article 4 of UK Double Taxation Avoidance Agreement: Key Criteria and Resolution Methods</h1> Article 4 of the Double Taxation Avoidance Agreement (DTAA) between the UK and another contracting state defines the term 'resident of a Contracting State' for taxation purposes. A resident is someone liable to tax due to domicile, residence, 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 determined by mutual agreement between states, considering factors like effective management and incorporation. Absent agreement, tax relief is limited.
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