Tax residency tie breaker rules determine which state treats an individual as resident for treaty purposes.

The Article defines a resident of a Contracting State as a person liable to tax there by domicile, residence, place of management or similar criterion, including the State itself but excluding persons taxable only on source income. For individuals who are residents of both States, a tie breaker sequence-permanent home, centre of vital interests, habitual abode, nationality, and then mutual agreement-determines residence. For non individuals resident in both States, residence is determined by the place of effective management, with unresolved cases settled by mutual agreement.

---

---

---