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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Clarifying Residency Criteria Under Article 4 of DTAA: Domicile, Permanent Home, and Effective Management Explained.</h1> Article 4 of the Double Tax Avoidance Agreement (DTAA) defines 'resident of a Contracting State' for tax purposes, based on domicile, residence, or management criteria. If an individual is considered a resident of both Contracting States, residency is determined by the location of their permanent home, center of vital interests, habitual abode, or nationality. If these criteria do not resolve the issue, the competent authorities will reach a mutual agreement. For entities other than individuals, residency is determined by the location of their place of effective management.
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