Article 4 - Resident

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..... ture, and also 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 .....

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..... he has an habitual abode in both States or in neither of them , he shall be deemed to be a resident only of 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 ot .....

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..... greed upon by the competent authorities of the Contracting States. [ Para 3 of Article 4 ] This will not prevent the taxpayer from being considered a resident of each Contracting State for purpose other than granting treaty reliefs or exemptions to that person. Note The situation of Dual residence may arise in case of companies in case where one Contracting State attaches .....

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