https://www.taxtmi.com/acts?id=44689 Article 4 defines a resident of a Contracting State by reference to domestic criteria. For individuals with dual residency, residence is fixed by a hierarchy: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement. For entities, the MLI requires competent authorities to determine residence by mutual agreement considering place of effective management, place of incorporation or constitution and other relevant factors; without agreement, treaty benefits are limited to any extent agreed by those authorities. en-us Wed, 16 Oct 2024 13:11:17 +0530 Wed, 23 Oct 2024 16:15:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44689 Article 4 defines a resident of a Contracting State by reference to domestic criteria. For individuals with dual residency, residence is fixed by a hierarchy: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement. For entities, the MLI requires competent authorities to determine residence by mutual agreement considering place of effective management, place of incorporation or constitution and other relevant factors; without agreement, treaty benefits are limited to any extent agreed by those authorities. Act-Rules DTAA Wed, 16 Oct 2024 13:11:17 +0530 https://www.taxtmi.com/acts?id=44689