Fiscal domicile rules determine treaty residence using permanent home, centre of vital interests, habitual abode and nationality.

Defines resident of a Contracting State as any person liable to taxation there by domicile, residence, place of management or similar criterion. For individuals resident in both States, a hierarchy determines residence: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement. For non individuals resident in both States, residence is determined by the place of effective management.

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