https://www.taxtmi.com/acts?id=45538 Article 4 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 source income. For individuals with dual residence, tie breaker rules apply in sequence: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement by competent authorities. For dual resident entities the MLI procedure requires competent authorities to determine residence by mutual agreement considering effective management, place of incorporation and other relevant factors; absent agreement, treaty relief is limited to what authorities agree. en-us Fri, 18 Oct 2024 16:22:58 +0530 Tue, 22 Oct 2024 18:20:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45538 Article 4 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 source income. For individuals with dual residence, tie breaker rules apply in sequence: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement by competent authorities. For dual resident entities the MLI procedure requires competent authorities to determine residence by mutual agreement considering effective management, place of incorporation and other relevant factors; absent agreement, treaty relief is limited to what authorities agree. Act-Rules DTAA Fri, 18 Oct 2024 16:22:58 +0530 https://www.taxtmi.com/acts?id=45538