https://www.taxtmi.com/acts?id=6155 The Article defines resident as a person liable to tax in a Contracting State by reason of domicile, residence, place of management, place of incorporation or similar criteria, excluding persons taxed only on source income and limiting partnership/estate/trust residency to income taxed as resident. Dual-resident individuals are assigned residence by sequential tie-breakers: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement. Dual-resident non-individuals are resident where their place of effective management is situated. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 24 Dec 2024 16:14:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6155 The Article defines resident as a person liable to tax in a Contracting State by reason of domicile, residence, place of management, place of incorporation or similar criteria, excluding persons taxed only on source income and limiting partnership/estate/trust residency to income taxed as resident. Dual-resident individuals are assigned residence by sequential tie-breakers: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement. Dual-resident non-individuals are resident where their place of effective management is situated. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6155