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of <h1>Article 4 of DTAA Defines Residency for Tax Purposes, Modified by MLI for Dual Resident Entities</h1> Article 4 of the Double Taxation Avoidance Agreement (DTAA) between Poland and another Contracting State defines 'resident of a Contracting State' as a person liable to tax in that state due to domicile, residence, or management location, 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 effective management location, with mutual agreement required if dual residency persists. The Multilateral Instrument (MLI) modifies these provisions for dual resident entities.
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