https://www.taxtmi.com/acts?id=16774 Defines treaty "resident" as a person liable to tax by reason of domicile, residence, place of management, place of incorporation or similar criteria, excluding persons taxable only on in state source income. For dual resident individuals the treaty sets a hierarchical tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and failing those the competent authorities decide. For dual resident non individuals authorities should seek agreement based on place of incorporation, place of effective management and other factors; without agreement the entity cannot claim treaty benefits. en-us Tue, 31 Jul 2012 12:18:51 +0530 Tue, 26 Nov 2024 10:47:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=16774 Defines treaty "resident" as a person liable to tax by reason of domicile, residence, place of management, place of incorporation or similar criteria, excluding persons taxable only on in state source income. For dual resident individuals the treaty sets a hierarchical tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and failing those the competent authorities decide. For dual resident non individuals authorities should seek agreement based on place of incorporation, place of effective management and other factors; without agreement the entity cannot claim treaty benefits. Act-Rules DTAA Tue, 31 Jul 2012 12:18:51 +0530 https://www.taxtmi.com/acts?id=16774