https://www.taxtmi.com/acts?id=44658 The term resident of a Contracting State means any person liable to tax there by domicile, residence, place of management or similar criterion, excluding those taxed only on income from local sources. For dual resident individuals the treaty applies a hierarchical tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement if needed. For dual resident entities residency is determined by place of effective management, with unresolved cases to be settled by the competent authorities through mutual agreement. en-us Wed, 16 Oct 2024 12:41:49 +0530 Tue, 22 Oct 2024 11:29:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44658 The term resident of a Contracting State means any person liable to tax there by domicile, residence, place of management or similar criterion, excluding those taxed only on income from local sources. For dual resident individuals the treaty applies a hierarchical tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement if needed. For dual resident entities residency is determined by place of effective management, with unresolved cases to be settled by the competent authorities through mutual agreement. Act-Rules DTAA Wed, 16 Oct 2024 12:41:49 +0530 https://www.taxtmi.com/acts?id=44658