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

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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