Residence tie breaker rules determine which State an individual is resident of using permanent home, centre of vital interests, habitual abode.

The Agreement defines resident as any person liable to tax in a Contracting State by criteria such as domicile, residence, place of management or registration, but excludes persons taxable only on in State source income. For individuals dual resident, a hierarchy of tie breakers applies: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement of competent authorities. For non individual dual residents, residence is determined by the place of effective management; if indeterminate, competent authorities should agree and, failing agreement, the person is not treated as a resident of either State for treaty benefits.

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