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Introducing the βIn Favour Ofβ filter in Case Laws.
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<h1>Article 4 of DTAA: Defines 'Resident' for Tax Purposes; Criteria Include Domicile, Permanent Home, and Effective 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 the state. If an individual is a resident of both states, residency is determined by the location of a permanent home, center of vital interests, habitual abode, or nationality. For entities, residency is determined by the place of effective management. If residency cannot be determined, the competent authorities will resolve the issue through mutual agreement.