https://www.taxtmi.com/acts?id=44782 The Agreement defines "resident of a Contracting State" as any person liable to tax there by reason of domicile, residence, place of management, place of incorporation or similar criterion, excluding persons taxable only on source income. For individuals resident in both States, treaty residence is determined by a sequential tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement by competent authorities. For non individuals resident in both States, the competent authorities decide residence by mutual agreement considering place of incorporation, place of effective management and other relevant factors. en-us Wed, 16 Oct 2024 15:02:43 +0530 Tue, 22 Oct 2024 13:24:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44782 The Agreement defines "resident of a Contracting State" as any person liable to tax there by reason of domicile, residence, place of management, place of incorporation or similar criterion, excluding persons taxable only on source income. For individuals resident in both States, treaty residence is determined by a sequential tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement by competent authorities. For non individuals resident in both States, the competent authorities decide residence by mutual agreement considering place of incorporation, place of effective management and other relevant factors. Act-Rules DTAA Wed, 16 Oct 2024 15:02:43 +0530 https://www.taxtmi.com/acts?id=44782