Resident

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....ver, does not include any person who is liable to tax in India in respect only of income from sources in India; and (b) in the case of the United Arab Emirates: an individual who is present in the UAE for a period or periods totalling in the aggregate at least 183 days in the calendar year concerned, and a company which is incorporated in the UAE and which is managed and controlled wholly in UA....

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....vision or local authority/ governments which are recognized as such by mutual agreement of the competent authorities of the Contracting States. (d) For the purposes of this Article, Abu Dhabi Investment Authority is recognized as a resident of the United Arab Emirates.] ^2[3.] Where by reason of the provisions of paragraph (1), an individual is a resident of both Contracting State, then his ....

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....al of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement. ^3[4.] Where by reason of the provisions of paragraph (1), a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the State in which its place of effective management is situated.   ....