Tax residency determination sets tie breaker rules prioritising permanent home, centre of vital interests, habitual abode, nationality.

The Convention defines a resident of a Contracting State as a person liable to tax there by domicile, residence, place of management or similar criteria, excluding those taxable only on in State source income. Where an individual is resident of both States, residency is allocated by sequential tie breaker tests: permanent home, centre of vital interests, habitual abode, nationality, and, if unresolved, mutual agreement by competent authorities. For non individuals resident of both States, residency is determined by place of effective management, or by mutual agreement if indeterminate.

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