https://www.taxtmi.com/acts?id=4499 The treaty defines resident of a Contracting State by domestic tax liability and sets hierarchical tie breaker rules for dual resident individuals-permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement. For non individuals resident in both States, the competent authorities must endeavour to determine residence by reference to place of effective management, place of incorporation or other relevant factors, and absent agreement relief under the Agreement may be limited as agreed by those authorities. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 08 Nov 2024 15:31:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4499 The treaty defines resident of a Contracting State by domestic tax liability and sets hierarchical tie breaker rules for dual resident individuals-permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement. For non individuals resident in both States, the competent authorities must endeavour to determine residence by reference to place of effective management, place of incorporation or other relevant factors, and absent agreement relief under the Agreement may be limited as agreed by those authorities. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4499