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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' and Resolves Dual Residency Conflicts Through Mutual Agreement and Effective Management.</h1> Article 4 of the Double Taxation Avoidance Agreement (DTAA) between two contracting states defines a 'resident' as any person liable to tax in a state due to domicile, residence, or similar criteria, excluding those taxed only on income from sources within that state. For individuals deemed residents of both states, residency is determined by permanent home, center of vital interests, habitual abode, or nationality, with unresolved cases settled by mutual agreement. For entities, residency is based on the location of effective management, with unresolved cases also settled by mutual agreement between state authorities.
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