https://www.taxtmi.com/acts?id=6046 The Convention defines resident of a Contracting State as anyone liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on local-source income or local capital. For individuals who are residents of both States, a tie breaker hierarchy applies: permanent home; centre of vital interests; habitual abode; nationality; and, if unresolved, mutual agreement by competent authorities. Non individual dual residents are deemed residents of the State of their place of effective management. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 03 Dec 2024 11:09:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6046 The Convention defines resident of a Contracting State as anyone liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on local-source income or local capital. For individuals who are residents of both States, a tie breaker hierarchy applies: permanent home; centre of vital interests; habitual abode; nationality; and, if unresolved, mutual agreement by competent authorities. Non individual dual residents are deemed residents of the State of their place of effective management. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6046