https://www.taxtmi.com/acts?id=44813 The Agreement defines resident of a Contracting State as persons liable to tax there by domicile, residence, place of management or similar criteria, excluding those taxable only on in state source income or in state capital. Dual resident individuals are allocated residence by a sequential tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and failing those the competent authorities must seek mutual agreement. Dual residency for non individuals is resolved by place of effective management; if indeterminate, competent authorities seek agreement and absent agreement the person is not a resident of either State for treaty benefits. en-us Wed, 16 Oct 2024 15:35:25 +0530 Tue, 22 Oct 2024 13:00:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44813 The Agreement defines resident of a Contracting State as persons liable to tax there by domicile, residence, place of management or similar criteria, excluding those taxable only on in state source income or in state capital. Dual resident individuals are allocated residence by a sequential tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and failing those the competent authorities must seek mutual agreement. Dual residency for non individuals is resolved by place of effective management; if indeterminate, competent authorities seek agreement and absent agreement the person is not a resident of either State for treaty benefits. Act-Rules DTAA Wed, 16 Oct 2024 15:35:25 +0530 https://www.taxtmi.com/acts?id=44813