https://www.taxtmi.com/acts?id=44845 The Convention defines a 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 criteria, excluding persons taxable only on domestic-source income. For individuals with dual residency a hierarchical tie breaker applies: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement by competent authorities. For non individuals with dual residency, residency is determined by the place of effective management, with unresolved cases settled by mutual agreement. en-us Wed, 16 Oct 2024 15:51:30 +0530 Tue, 22 Oct 2024 15:08:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44845 The Convention defines a 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 criteria, excluding persons taxable only on domestic-source income. For individuals with dual residency a hierarchical tie breaker applies: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement by competent authorities. For non individuals with dual residency, residency is determined by the place of effective management, with unresolved cases settled by mutual agreement. Act-Rules DTAA Wed, 16 Oct 2024 15:51:30 +0530 https://www.taxtmi.com/acts?id=44845