Fiscal Residence

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..... tical subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State. ] 2. Where by reason of the provisions of paragraph 1, an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident of the State in wh .....

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..... e the question by mutual agreement. 3. [REPLACED by paragraph 1 of Article 4 of the MLI ] [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.] The following paragraph 1 of Article 4 of the MLI replaces paragraph 3 o .....

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..... the [Contracting States]. **************** NOTES:- 1 . Substituted vide Notification No. 47/2014 dated 24-09-2014 before it was read as, 1. For the purposes of this Agreement, the term resident of a Contracting State means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature. - .....

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