Resident determination under DTAA: tie breaker rules allocate residency by permanent home, centre of vital interests, habitual abode, nationality.

The Article defines a "resident of a Contracting State" as a person liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on income from sources in that State. Where an individual is resident of both States, residency is resolved by tie breaker rules: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement by competent authorities. For non individuals, residency is determined by the place of effective management or, if indeterminate, by mutual agreement.

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