https://www.taxtmi.com/acts?id=8867 Determination of resident of a Contracting State identifies persons liable to tax by domicile, residence, place of management or similar criteria, excluding those taxed only on local source income. For individuals resident in both Contracting States a sequential tie breaker applies: permanent home, centre of vital interests, habitual abode, nationality, and, if still unresolved, mutual agreement between competent authorities. For persons other than individuals who are residents of both States, residence is determined by the place of effective management, with unresolved cases referred to mutual agreement between competent authorities. en-us Sat, 21 Jun 2008 11:20:45 +0530 Wed, 06 Nov 2024 15:18:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=8867 Determination of resident of a Contracting State identifies persons liable to tax by domicile, residence, place of management or similar criteria, excluding those taxed only on local source income. For individuals resident in both Contracting States a sequential tie breaker applies: permanent home, centre of vital interests, habitual abode, nationality, and, if still unresolved, mutual agreement between competent authorities. For persons other than individuals who are residents of both States, residence is determined by the place of effective management, with unresolved cases referred to mutual agreement between competent authorities. Act-Rules DTAA Sat, 21 Jun 2008 11:20:45 +0530 https://www.taxtmi.com/acts?id=8867