Tax residence tie breaker rules determine residency by permanent home, centre of vital interests, habitual abode, nationality, or mutual agreement.

Definition of resident under the DTAA covers persons taxable by reason of domicile, residence, place of management, place of registration or similar criteria. Where an individual is resident of both Contracting States, residency is resolved by a sequential tie breaker: permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement of competent authorities. For non individuals resident of both States, residency is determined by the State of the place of effective management.

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