Article 4 - Resident - Overview of Model Tax Convention - CA Arinjay Jain +91-9667714335 скачать в хорошем качестве

Article 4 - Resident - Overview of Model Tax Convention - CA Arinjay Jain +91-9667714335

Full Course Android App - https://play.google.com/store/apps/de... For consultancy on International tax issues, call our experts by subscribing to one of our Plans For more info visit - https://sortingtax.com/talk-to-tax-pr... Contact us :- Email - contact@sortingtax.com Phone Number - +91-9667714335 Follow us on Linked in -   / arinjay-jain-95829a28   #Internationaltax #taxexpert #taxconsultant #taxadvice #permanentestablishment #feefortechnicalservices #DTAA #Treaty #MLI #BEPS Article 4 - Resident - Overview of Model Tax Convention - CA Arinjay Jain - CA Final International Taxation Elective Paper 6C ARTICLE 4 – RESIDENCE - GENERAL STRUCTURE This Article provides the criteria as to who shall be considered a resident of a Contracting State. In case the application of such a criteria results in dual residency, the rules of determining the residential status of a person (tie breaker rule) are generally provided in the tax Treaty, which are separate for an individual and separate for non-individuals. The general structure of Article 4 is as under : - • Article 4 (1) - Definition of a resident • Article 4 (2) - Tie breaker rules for an individual • Article 4 (3) - Tie breaker rules for non- individuals Importance of concept of residence lies in the fact that it helps in the following : - • Determine the scope and application of the Treaty • Allocate taxing rights between Treaty partners • Ascertain fiscal domicile of a company • Resolving cases of double taxation