https://www.taxtmi.com/acts?id=51400 Residency for treaty purposes is based on liability to tax under domestic law and excludes persons taxed only on in State source income or capital. Dual resident individuals are allocated residence by a sequential tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement of competent authorities. Dual residency for non individuals is resolved by mutual agreement considering place of effective management, place of incorporation or constitution and other relevant factors; absent agreement, treaty relief or exemption is not available except as the competent authorities may agree. en-us Thu, 22 May 2025 11:55:35 +0530 Tue, 27 May 2025 12:10:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=51400 Residency for treaty purposes is based on liability to tax under domestic law and excludes persons taxed only on in State source income or capital. Dual resident individuals are allocated residence by a sequential tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement of competent authorities. Dual residency for non individuals is resolved by mutual agreement considering place of effective management, place of incorporation or constitution and other relevant factors; absent agreement, treaty relief or exemption is not available except as the competent authorities may agree. Act-Rules DTAA Thu, 22 May 2025 11:55:35 +0530 https://www.taxtmi.com/acts?id=51400