https://www.taxtmi.com/acts?id=45162 The provision defines resident of a Contracting State as a person liable to tax there by domicile, residence, place of management or similar criteria, excluding persons taxable only on income from sources within that State and limiting application to partnerships, estates or trusts to the extent their income is taxed as resident income. For dual resident individuals a hierarchical tie breaker applies (permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement). For dual resident entities the MLI requires competent authorities to determine residence by place of effective management, place of incorporation and other factors, with treaty relief dependent on any agreement reached. en-us Thu, 17 Oct 2024 16:12:36 +0530 Tue, 22 Oct 2024 12:24:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45162 The provision defines resident of a Contracting State as a person liable to tax there by domicile, residence, place of management or similar criteria, excluding persons taxable only on income from sources within that State and limiting application to partnerships, estates or trusts to the extent their income is taxed as resident income. For dual resident individuals a hierarchical tie breaker applies (permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement). For dual resident entities the MLI requires competent authorities to determine residence by place of effective management, place of incorporation and other factors, with treaty relief dependent on any agreement reached. Act-Rules DTAA Thu, 17 Oct 2024 16:12:36 +0530 https://www.taxtmi.com/acts?id=45162