https://www.taxtmi.com/caselaws?id=159599 Treaty residence under the India-UAE double taxation agreement was held to require actual liability to tax in the UAE. Because an individual was not liable to income-tax in the UAE, he could not qualify as a "resident of a Contracting State" under article 4 and therefore could not invoke the concessional rates or exemptions in articles 10, 11 and 13. The tie-breaker rules in article 4(2) were treated as inapplicable where residence in both States was absent. The analysis also stated that treaty relief is confined to cases involving double taxation or corresponding foreign taxation, which was not present here. en-us Wed, 19 May 1999 00:00:00 +0530 Fri, 23 Oct 2015 17:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=159599 Treaty residence under the India-UAE double taxation agreement was held to require actual liability to tax in the UAE. Because an individual was not liable to income-tax in the UAE, he could not qualify as a "resident of a Contracting State" under article 4 and therefore could not invoke the concessional rates or exemptions in articles 10, 11 and 13. The tie-breaker rules in article 4(2) were treated as inapplicable where residence in both States was absent. The analysis also stated that treaty relief is confined to cases involving double taxation or corresponding foreign taxation, which was not present here. Case-Laws Income Tax Wed, 19 May 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=159599