https://www.taxtmi.com/acts?id=37635 Article 4 defines resident as any person liable to tax in a Contracting State by domicile, residence, place of incorporation, place of management or similar criteria, including the State and its subdivisions, but excluding persons taxable solely on source income. For dual resident individuals a hierarchy of tie breakers applies: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement between competent authorities. For dual resident entities residence is determined by place of effective management, or otherwise by mutual agreement of the competent authorities. en-us Thu, 19 Sep 2019 12:11:58 +0530 Tue, 26 Nov 2024 17:32:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=37635 Article 4 defines resident as any person liable to tax in a Contracting State by domicile, residence, place of incorporation, place of management or similar criteria, including the State and its subdivisions, but excluding persons taxable solely on source income. For dual resident individuals a hierarchy of tie breakers applies: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement between competent authorities. For dual resident entities residence is determined by place of effective management, or otherwise by mutual agreement of the competent authorities. Act-Rules DTAA Thu, 19 Sep 2019 12:11:58 +0530 https://www.taxtmi.com/acts?id=37635