Personal scope of DTAA: residency determines treaty application to persons resident in one or both contracting states.

The Agreement sets a treaty framework for avoidance of double taxation and prevention of fiscal evasion in respect of taxes on income. Its personal scope applies the treaty to persons who are residents of one or both Contracting States, thereby making residency the basis for access to treaty benefits. Domestic notification directs that the treaty be given effect within the national legal system to operate with domestic tax law for income taxation.

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