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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 4 of DTAA: Defines 'resident' for tax purposes, clarifying criteria for individuals and non-individuals across contracting states.</h1> Article 4 of the Double Taxation Avoidance Agreement (DTAA) between Poland and another contracting state defines 'resident of a Contracting State' as any person liable to tax due to domicile, residence, place of management, or similar criteria, excluding those taxed solely on income from sources within that state. For individuals considered residents of both states, residency is determined by the location of a permanent home, center of vital interests, habitual abode, or nationality. If unresolved, authorities will mutually agree. For non-individuals, residency is based on the place of effective management.
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