https://www.taxtmi.com/acts?id=45065 The Article defines resident of a Contracting State as any person liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on income or capital from sources in that State. Dual resident individuals are subject to sequential tie breakers: permanent home; centre of vital interests; habitual abode; nationality; and, if unresolved, mutual agreement by competent authorities. Dual resident entities are deemed resident where their place of effective management is situated, with unresolved cases referred to competent authorities for mutual agreement. en-us Wed, 16 Oct 2024 18:22:58 +0530 Tue, 22 Oct 2024 14:18:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45065 The Article defines resident of a Contracting State as any person liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on income or capital from sources in that State. Dual resident individuals are subject to sequential tie breakers: permanent home; centre of vital interests; habitual abode; nationality; and, if unresolved, mutual agreement by competent authorities. Dual resident entities are deemed resident where their place of effective management is situated, with unresolved cases referred to competent authorities for mutual agreement. Act-Rules DTAA Wed, 16 Oct 2024 18:22:58 +0530 https://www.taxtmi.com/acts?id=45065