https://www.taxtmi.com/acts?id=52146 The provision defines resident of a Contracting State as any person liable to tax in that State by domicile, residence, place of management or similar criteria, excluding those taxable only on source income. Dual resident individuals are assigned residence by tie breaker rules: centre of vital interests, habitual abode, nationality, then mutual agreement of competent authorities. Dual resident non individuals are resolved by mutual agreement considering place of effective management and place of incorporation; absent agreement, treaty relief is unavailable except as competent authorities may decide. en-us Tue, 04 Nov 2025 17:22:32 +0530 Tue, 04 Nov 2025 17:22:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=52146 The provision defines resident of a Contracting State as any person liable to tax in that State by domicile, residence, place of management or similar criteria, excluding those taxable only on source income. Dual resident individuals are assigned residence by tie breaker rules: centre of vital interests, habitual abode, nationality, then mutual agreement of competent authorities. Dual resident non individuals are resolved by mutual agreement considering place of effective management and place of incorporation; absent agreement, treaty relief is unavailable except as competent authorities may decide. Act-Rules DTAA Tue, 04 Nov 2025 17:22:32 +0530 https://www.taxtmi.com/acts?id=52146