https://www.taxtmi.com/acts?id=5536 Defines "resident of a Contracting State" as persons liable to tax by domicile, residence, place of management or similar criterion, excluding persons taxed only on in State source income. Dual resident individuals are resolved by a hierarchy: permanent home; centre of vital interests if homes in both States; habitual abode if centre cannot be determined or no permanent home; nationality if habitual abode test is inconclusive; and finally mutual agreement of competent authorities. Dual resident entities are resident in the State of their place of effective management, or otherwise resolved by mutual agreement of competent authorities. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 18 Nov 2024 16:45:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5536 Defines "resident of a Contracting State" as persons liable to tax by domicile, residence, place of management or similar criterion, excluding persons taxed only on in State source income. Dual resident individuals are resolved by a hierarchy: permanent home; centre of vital interests if homes in both States; habitual abode if centre cannot be determined or no permanent home; nationality if habitual abode test is inconclusive; and finally mutual agreement of competent authorities. Dual resident entities are resident in the State of their place of effective management, or otherwise resolved by mutual agreement of competent authorities. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5536