https://www.taxtmi.com/acts?id=6138 The Convention defines a resident of a Contracting State as any person liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on domestic-source income. For individuals with dual residence, a hierarchical tie breaker applies: permanent home, centre of vital interests, habitual abode, nationality, and failing these, mutual agreement of competent authorities. For non-individuals with dual residence, residence is determined by place of effective management, or otherwise by mutual agreement of the competent authorities. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 21 Nov 2024 15:42:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6138 The Convention defines a resident of a Contracting State as any person liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on domestic-source income. For individuals with dual residence, a hierarchical tie breaker applies: permanent home, centre of vital interests, habitual abode, nationality, and failing these, mutual agreement of competent authorities. For non-individuals with dual residence, residence is determined by place of effective management, or otherwise by mutual agreement of the competent authorities. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6138