https://www.taxtmi.com/acts?id=41702 The DTAA defines a "resident of a Contracting State" as any person liable to tax there by domicile, residence, place of management, place of incorporation or similar criteria, excluding those taxable only on in-state income or capital. For dual-resident individuals the treaty sets tie-breaker rules: permanent home, centre of vital interests, habitual abode, nationality, and failing those the competent authorities decide. For non-individual dual residents residence is the State of nationality, with mutual agreement procedures where nationality is shared or absent and no treaty relief if no agreement is reached. en-us Fri, 05 May 2023 16:27:40 +0530 Fri, 08 Nov 2024 14:32:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=41702 The DTAA defines a "resident of a Contracting State" as any person liable to tax there by domicile, residence, place of management, place of incorporation or similar criteria, excluding those taxable only on in-state income or capital. For dual-resident individuals the treaty sets tie-breaker rules: permanent home, centre of vital interests, habitual abode, nationality, and failing those the competent authorities decide. For non-individual dual residents residence is the State of nationality, with mutual agreement procedures where nationality is shared or absent and no treaty relief if no agreement is reached. Act-Rules DTAA Fri, 05 May 2023 16:27:40 +0530 https://www.taxtmi.com/acts?id=41702