https://www.taxtmi.com/acts?id=51350 Definition of resident of a Contracting State covers persons liable to tax by domicile, residence, citizenship, place of management, place of incorporation or similar criteria and includes the State and its subdivisions, while excluding those taxed on a fixed fee basis or only on source income or permanent establishment profits; pension funds and qualifying charitable or educational organizations are included. For individuals who are dual residents, a hierarchical tie breaker applies-permanent home, centre of vital interests, habitual abode, nationality-with unresolved cases referred to competent authorities for mutual agreement; dual resident companies cannot claim Convention benefits. en-us Wed, 21 May 2025 15:29:23 +0530 Wed, 21 May 2025 15:29:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=51350 Definition of resident of a Contracting State covers persons liable to tax by domicile, residence, citizenship, place of management, place of incorporation or similar criteria and includes the State and its subdivisions, while excluding those taxed on a fixed fee basis or only on source income or permanent establishment profits; pension funds and qualifying charitable or educational organizations are included. For individuals who are dual residents, a hierarchical tie breaker applies-permanent home, centre of vital interests, habitual abode, nationality-with unresolved cases referred to competent authorities for mutual agreement; dual resident companies cannot claim Convention benefits. Act-Rules DTAA Wed, 21 May 2025 15:29:23 +0530 https://www.taxtmi.com/acts?id=51350