https://www.taxtmi.com/acts?id=23465 Article 4 defines resident of a Contracting State as any person liable to tax in that State by reason of domicile, residence, place of management or similar criteria, excluding those liable only on source income in that State. For dual resident individuals, residency is determined by a sequence of tie breakers: permanent home, centre of vital interests, habitual abode, nationality, and failing those the competent authorities resolve by mutual agreement. For entities other than individuals, residency is determined by the place of effective management, with unresolved cases settled by the competent authorities under the mutual agreement process. en-us Tue, 17 Jan 2017 10:01:53 +0530 Thu, 14 Nov 2024 16:38:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=23465 Article 4 defines resident of a Contracting State as any person liable to tax in that State by reason of domicile, residence, place of management or similar criteria, excluding those liable only on source income in that State. For dual resident individuals, residency is determined by a sequence of tie breakers: permanent home, centre of vital interests, habitual abode, nationality, and failing those the competent authorities resolve by mutual agreement. For entities other than individuals, residency is determined by the place of effective management, with unresolved cases settled by the competent authorities under the mutual agreement process. Act-Rules DTAA Tue, 17 Jan 2017 10:01:53 +0530 https://www.taxtmi.com/acts?id=23465