https://www.taxtmi.com/acts?id=45000 The term resident of a Contracting State covers persons liable to tax in that State by domicile, residence, place of management, place of incorporation or similar criteria, excluding those taxable only on in State source income or capital. Dual residency for individuals is resolved by tie breaker tests: permanent home, centre of vital interests, habitual abode, and nationality, with remaining disputes submitted to competent authorities. For entities, competent authorities seek agreement considering place of effective management, incorporation and other factors; without agreement, the entity is not treated as resident of either State for treaty benefits. en-us Wed, 16 Oct 2024 17:49:33 +0530 Tue, 22 Oct 2024 12:06:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45000 The term resident of a Contracting State covers persons liable to tax in that State by domicile, residence, place of management, place of incorporation or similar criteria, excluding those taxable only on in State source income or capital. Dual residency for individuals is resolved by tie breaker tests: permanent home, centre of vital interests, habitual abode, and nationality, with remaining disputes submitted to competent authorities. For entities, competent authorities seek agreement considering place of effective management, incorporation and other factors; without agreement, the entity is not treated as resident of either State for treaty benefits. Act-Rules DTAA Wed, 16 Oct 2024 17:49:33 +0530 https://www.taxtmi.com/acts?id=45000