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of <h1>Article 4 of DTAA: Defining Residency for Tax Purposes Based on Domicile, Vital Interests, and Management</h1> Article 4 of the Double Tax Avoidance Agreement (DTAA) defines a 'resident of a Contracting State' as a person liable to tax in that state due to domicile, residence, or similar criteria, excluding those taxed solely on income from sources within that state. If an individual is considered a resident 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 these criteria are inconclusive, the competent authorities of the states will resolve the issue by mutual agreement.
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