https://www.taxtmi.com/acts?id=34168 Article 4 defines resident for the treaty: Hong Kong residents include ordinarily resident individuals, those meeting presence tests, companies and other constitutions incorporated or normally managed or controlled in Hong Kong; India residents are persons liable to tax under Indian law by domicile, residence, place of management or similar criteria, excluding persons taxable only on India-source income. Dual resident individuals are assigned residence by permanent home, centre of vital interests, habitual abode, or right of abode/nationality; unresolved cases require competent authorities' mutual agreement. Dual residency for non individuals is resolved by competent authorities considering place of effective management, incorporation and other relevant factors, with treaty relief contingent on agreement. en-us Fri, 28 Dec 2018 16:37:09 +0530 Wed, 20 Nov 2024 18:24:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=34168 Article 4 defines resident for the treaty: Hong Kong residents include ordinarily resident individuals, those meeting presence tests, companies and other constitutions incorporated or normally managed or controlled in Hong Kong; India residents are persons liable to tax under Indian law by domicile, residence, place of management or similar criteria, excluding persons taxable only on India-source income. Dual resident individuals are assigned residence by permanent home, centre of vital interests, habitual abode, or right of abode/nationality; unresolved cases require competent authorities' mutual agreement. Dual residency for non individuals is resolved by competent authorities considering place of effective management, incorporation and other relevant factors, with treaty relief contingent on agreement. Act-Rules DTAA Fri, 28 Dec 2018 16:37:09 +0530 https://www.taxtmi.com/acts?id=34168