https://www.taxtmi.com/acts?id=18234 The Agreement defines resident as any person liable to tax in a Contracting State by criteria such as domicile, residence, place of management or registration, but excludes persons taxable only on in State source income. For individuals dual resident, a hierarchy of tie breakers applies: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement of competent authorities. For non individual dual residents, residence is determined by the place of effective management; if indeterminate, competent authorities should agree and, failing agreement, the person is not treated as a resident of either State for treaty benefits. en-us Sun, 23 Mar 2014 14:51:39 +0530 Wed, 28 Aug 2024 15:44:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=18234 The Agreement defines resident as any person liable to tax in a Contracting State by criteria such as domicile, residence, place of management or registration, but excludes persons taxable only on in State source income. For individuals dual resident, a hierarchy of tie breakers applies: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement of competent authorities. For non individual dual residents, residence is determined by the place of effective management; if indeterminate, competent authorities should agree and, failing agreement, the person is not treated as a resident of either State for treaty benefits. Act-Rules DTAA Sun, 23 Mar 2014 14:51:39 +0530 https://www.taxtmi.com/acts?id=18234