https://www.taxtmi.com/acts?id=45194 Article 4 defines resident as any person liable to tax by domicile, residence, registration, management or similar criterion and sets tie breaker rules for dual resident individuals based on permanent home, centre of vital interests, habitual abode, and nationality, with unresolved cases referred to competent authorities. For non individual dual residents, the MLI replacement requires competent authorities to determine residence by mutual agreement considering place of effective management, place of incorporation and other relevant factors, and absent agreement the entity is not entitled to treaty relief except as agreed by those authorities. en-us Thu, 17 Oct 2024 16:43:20 +0530 Tue, 22 Oct 2024 16:43:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45194 Article 4 defines resident as any person liable to tax by domicile, residence, registration, management or similar criterion and sets tie breaker rules for dual resident individuals based on permanent home, centre of vital interests, habitual abode, and nationality, with unresolved cases referred to competent authorities. For non individual dual residents, the MLI replacement requires competent authorities to determine residence by mutual agreement considering place of effective management, place of incorporation and other relevant factors, and absent agreement the entity is not entitled to treaty relief except as agreed by those authorities. Act-Rules DTAA Thu, 17 Oct 2024 16:43:20 +0530 https://www.taxtmi.com/acts?id=45194