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

The Convention treats a "resident of a Contracting State" as any person liable to tax there by domicile, residence, place of management, place of incorporation or similar criteria, excluding persons taxable only on in state source income and limiting application for partnerships, estates and trusts. For individuals who are residents of both States, tie breaker rules apply in sequence: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between competent authorities. Dual resident entities are governed by the MLI provision requiring mutual determination by competent authorities with reference to place of effective management, place of incorporation and other relevant factors, and restricting treaty relief absent such agreement.

---

---

---