https://www.taxtmi.com/acts?id=5059 The Article defines resident of a Contracting State as any person liable to tax therein by reason of domicile, residence, place of management or similar criteria, excluding persons taxable only on source based income. For individuals resident in both States, residency is resolved by availability of a permanent home, then centre of vital interests, then habitual abode, then nationality, and finally by mutual agreement of competent authorities. For non individuals resident in both States, residency is determined by the location of the place of effective management, or otherwise by mutual agreement of competent authorities. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 25 Nov 2024 15:54:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5059 The Article defines resident of a Contracting State as any person liable to tax therein by reason of domicile, residence, place of management or similar criteria, excluding persons taxable only on source based income. For individuals resident in both States, residency is resolved by availability of a permanent home, then centre of vital interests, then habitual abode, then nationality, and finally by mutual agreement of competent authorities. For non individuals resident in both States, residency is determined by the location of the place of effective management, or otherwise by mutual agreement of competent authorities. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5059