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of <h1>Unraveling Residency Criteria: Key Factors Determining Tax Status Under International Treaty Framework</h1> The statutory provision defines 'resident' for tax treaty purposes. It establishes criteria for determining residency, including domicile, residence, incorporation, and management. For individuals with dual residency, a hierarchical test applies: permanent home, center of vital interests, habitual abode, and nationality. For non-individual entities, competent authorities resolve residency through mutual agreement, considering factors like effective management and incorporation location. The definition aims to prevent double taxation and clarify tax jurisdiction.
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