Tax residence determination uses permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement.

Determination of resident of a Contracting State identifies persons liable to tax by domicile, residence, place of management or similar criteria, excluding those taxed only on local source income. For individuals resident in both Contracting States a sequential tie breaker applies: permanent home, centre of vital interests, habitual abode, nationality, and, if still unresolved, mutual agreement between competent authorities. For persons other than individuals who are residents of both States, residence is determined by the place of effective management, with unresolved cases referred to mutual agreement between competent authorities.

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