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of <h1>Understanding Residency: Article 4 of OECD Model Tax Convention & Section 6 of Indian Income Tax Act, 1961</h1> Article 4 of the OECD Model Tax Convention defines a 'resident of a contracting state' as any person liable to tax due to domicile, residence, or similar criteria, including political subdivisions and recognized pension funds. It excludes those taxed solely on income from sources within the state. For individuals deemed residents of both contracting states, residency is determined by permanent home, center of vital interests, habitual abode, or nationality. For non-individuals, residency is determined by mutual agreement or, lacking that, no treaty relief is granted. The UN Model Convention mirrors this, and the Indian Income Tax Act, 1961, addresses resident status in Section 6.
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