https://www.taxtmi.com/acts?id=4590 Article 4 defines resident of a Contracting State as a person liable to tax there by domicile, residence, place of management or similar criteria, excluding persons taxable only on local-source income or local-situated capital. Where an individual is resident of both Contracting States, residence is fixed by availability of a permanent home, then by centre of vital interests, then by habitual abode, then by nationality, and finally by mutual agreement of competent authorities. For non-individuals resident of both States, residence is the State of the place of effective management. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 15 Nov 2024 17:06:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4590 Article 4 defines resident of a Contracting State as a person liable to tax there by domicile, residence, place of management or similar criteria, excluding persons taxable only on local-source income or local-situated capital. Where an individual is resident of both Contracting States, residence is fixed by availability of a permanent home, then by centre of vital interests, then by habitual abode, then by nationality, and finally by mutual agreement of competent authorities. For non-individuals resident of both States, residence is the State of the place of effective management. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4590