https://www.taxtmi.com/acts?id=37667 The Article defines a resident of a Contracting State as a person liable to tax there by domicile, residence, place of management or similar criterion, including the State itself but excluding persons taxable only on source income. For individuals who are residents of both States, a tie breaker sequence-permanent home, centre of vital interests, habitual abode, nationality, and then mutual agreement-determines residence. For non individuals resident in both States, residence is determined by the place of effective management, with unresolved cases settled by mutual agreement. en-us Thu, 19 Sep 2019 12:48:23 +0530 Mon, 09 Dec 2024 11:34:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=37667 The Article defines a resident of a Contracting State as a person liable to tax there by domicile, residence, place of management or similar criterion, including the State itself but excluding persons taxable only on source income. For individuals who are residents of both States, a tie breaker sequence-permanent home, centre of vital interests, habitual abode, nationality, and then mutual agreement-determines residence. For non individuals resident in both States, residence is determined by the place of effective management, with unresolved cases settled by mutual agreement. Act-Rules DTAA Thu, 19 Sep 2019 12:48:23 +0530 https://www.taxtmi.com/acts?id=37667