https://www.taxtmi.com/acts?id=45312 The Convention defines resident as a person liable to tax by domicile, residence, place of management or similar criteria, excluding those taxable only on in state source income. Dual resident individuals are subject to sequential tie breaker rules: permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement if unresolved. Dual resident entities are resolved under the MLI by mutual agreement, considering place of effective management, place of incorporation or constitution and other relevant factors, and absent agreement are not entitled to Convention relief except as agreed by competent authorities. en-us Fri, 18 Oct 2024 11:51:37 +0530 Fri, 18 Oct 2024 11:51:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45312 The Convention defines resident as a person liable to tax by domicile, residence, place of management or similar criteria, excluding those taxable only on in state source income. Dual resident individuals are subject to sequential tie breaker rules: permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement if unresolved. Dual resident entities are resolved under the MLI by mutual agreement, considering place of effective management, place of incorporation or constitution and other relevant factors, and absent agreement are not entitled to Convention relief except as agreed by competent authorities. Act-Rules DTAA Fri, 18 Oct 2024 11:51:37 +0530 https://www.taxtmi.com/acts?id=45312