https://www.taxtmi.com/acts?id=32256 The Article defines resident of a Contracting State as a person liable to tax there by domicile, residence, place of incorporation, place of management or similar criterion, excluding persons taxable only on in state source income. For dual resident individuals it prescribes a hierarchical tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and referral to competent authorities if unresolved. For non individuals it attributes residence to the State of the entity's place of effective management, with unresolved cases to be settled by mutual agreement of the competent authorities. en-us Tue, 15 May 2018 17:26:55 +0530 Mon, 09 Dec 2024 11:22:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=32256 The Article defines resident of a Contracting State as a person liable to tax there by domicile, residence, place of incorporation, place of management or similar criterion, excluding persons taxable only on in state source income. For dual resident individuals it prescribes a hierarchical tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and referral to competent authorities if unresolved. For non individuals it attributes residence to the State of the entity's place of effective management, with unresolved cases to be settled by mutual agreement of the competent authorities. Act-Rules DTAA Tue, 15 May 2018 17:26:55 +0530 https://www.taxtmi.com/acts?id=32256