https://www.taxtmi.com/acts?id=16561 Resident of a Contracting State means any person liable to tax there by domicile, residence, place of management or similar criterion, including the State and its subdivisions, but excluding persons taxable there only on source income or local capital. Individuals dual resident are allocated residency by a hierarchy: permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement. Non individuals dual resident are resident where their place of effective management is situated; if indeterminate, competent authorities should seek mutual agreement, otherwise they are not treated as resident of either State for treaty benefits. en-us Wed, 30 May 2012 15:43:37 +0530 Tue, 19 Nov 2024 17:49:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=16561 Resident of a Contracting State means any person liable to tax there by domicile, residence, place of management or similar criterion, including the State and its subdivisions, but excluding persons taxable there only on source income or local capital. Individuals dual resident are allocated residency by a hierarchy: permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement. Non individuals dual resident are resident where their place of effective management is situated; if indeterminate, competent authorities should seek mutual agreement, otherwise they are not treated as resident of either State for treaty benefits. Act-Rules DTAA Wed, 30 May 2012 15:43:37 +0530 https://www.taxtmi.com/acts?id=16561