Dual resident entities tie-breaker: residency decided by management or incorporation; no treaty benefits absent agreement.

The Convention defines a resident of a Contracting State by liability to tax under that State's laws based on domicile, residence, place of head or main office or similar criteria. If a person is resident of both States, competent authorities shall determine by mutual agreement the State of residence. For entities, the MLI-modified rule directs consideration of place of effective management, place of incorporation or constitution and other relevant factors; absent agreement, the dual resident entity is not entitled to treaty relief or exemption.

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