https://www.taxtmi.com/caselaws?id=6583 An individual must be presently liable to tax in the claimed State of residence to qualify as a "resident of a Contracting State" under Article 4(1) of the India-UAE treaty. Mere physical residence in the UAE, or possible future taxability, does not satisfy the treaty definition where the person is not a taxable unit under UAE domestic law. The treaty's personal scope therefore does not extend to that individual, and the distributive provisions for dividend, interest and capital gains income cannot be invoked on that basis. en-us Mon, 09 May 2005 00:00:00 +0530 Thu, 15 Jan 2009 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6583 An individual must be presently liable to tax in the claimed State of residence to qualify as a "resident of a Contracting State" under Article 4(1) of the India-UAE treaty. Mere physical residence in the UAE, or possible future taxability, does not satisfy the treaty definition where the person is not a taxable unit under UAE domestic law. The treaty's personal scope therefore does not extend to that individual, and the distributive provisions for dividend, interest and capital gains income cannot be invoked on that basis. Case-Laws Income Tax Mon, 09 May 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6583