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Article 4 - DTAA - Article 4 - ARTICLE 4 1. For the purposes of this Agreement, the term " 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 and also includes that State and any political 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 f .....

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is centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a 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 endeavor to settle the question by mutu .....

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