Article 4 - Resident

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....so * Includes * that State and any political subdivision or local authority thereof as well as a recognised pension fund of that State. * Exclude * any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein. [ Para 1 of Article 4 ] Article 4 Individual also include in Resident if he is resident of both contracting state ....

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....the State of which he is a national; * d) if he is a national of both States or of neither of them, * the competent authorities of the Contracting States shall settle the question by mutual agreement. [ Para 2 of Article 4 ] Article 4 also include other than Individual is a resident of both Contracting States A person other than an individual is a resident of both Contracting States, * In....