Resident

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..... e any person who is liable to tax in India in respect only of income from sources in India; (b) in South Africa, any individual who is ordinarily resident in South Africa and any other person which has its place of effective management in South Africa. 2. Where by reason of the provisions of paragraph 1, an individual is a resident of both Contracting States, then his status shall be determine .....

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..... horities of the Contracting States shall settle the question by mutual agreement. 3. 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 only of the State in which its place of effective management is situated. If the State in which its place of effective management is situated cann .....

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