https://www.taxtmi.com/acts?id=4705 The Article defines resident of a Contracting State as a person liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding those taxed only on source income or local capital. For dual resident individuals, residence is resolved by tie breakers in sequence: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement of competent authorities. Dual residence for non individuals is resolved by the location of the entity's place of effective management. en-us Sat, 19 Jan 2008 22:45:54 +0530 Wed, 20 Nov 2024 14:18:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4705 The Article defines resident of a Contracting State as a person liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding those taxed only on source income or local capital. For dual resident individuals, residence is resolved by tie breakers in sequence: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement of competent authorities. Dual residence for non individuals is resolved by the location of the entity's place of effective management. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4705