Section 3 in Agreement between the Government of the Republic of India and the Government of the Republic of South Africa for the Avoidance of double taxation and the prevention of fiscal evasion with respect to Taxes on income
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 cannot be determined, then the competent authorities of the Contracting States shall settle the question by mutual agreement.
