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of <h1>Article 4 of DTAA Clarifies Tax Residency Rules for Individuals and Entities Between India and South Africa</h1> Article 4 of the Double Tax Avoidance Agreement (DTAA) between India and South Africa defines 'resident of a Contracting State' for tax purposes. In India, a resident is any person liable to tax by domicile or similar criteria, excluding those taxed only on Indian-sourced income. In South Africa, a resident is an individual ordinarily resident or an entity with effective management in South Africa. For dual residents, residency is determined by permanent home, center of vital interests, habitual abode, or nationality. For non-individuals, residency is based on the place of effective management, with disputes resolved by mutual agreement.
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