https://www.taxtmi.com/acts?id=15084 A "resident of a Contracting State" is any person liable to tax there by domicile, residence, place of management or similar criterion, excluding those taxable only on source income. For individuals resident in both States, residency is determined by permanent home availability, then centre of vital interests, then habitual abode, then nationality, and finally mutual agreement if unresolved. For entities resident in both States, residency is determined by place of effective management, or by mutual agreement if that cannot be determined. en-us Tue, 30 Aug 2011 14:34:18 +0530 Thu, 28 Nov 2024 15:28:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=15084 A "resident of a Contracting State" is any person liable to tax there by domicile, residence, place of management or similar criterion, excluding those taxable only on source income. For individuals resident in both States, residency is determined by permanent home availability, then centre of vital interests, then habitual abode, then nationality, and finally mutual agreement if unresolved. For entities resident in both States, residency is determined by place of effective management, or by mutual agreement if that cannot be determined. Act-Rules DTAA Tue, 30 Aug 2011 14:34:18 +0530 https://www.taxtmi.com/acts?id=15084