Residence tie-breaker rules determine single State residency for treaty taxation based on home, vital interests, abode, nationality.

Article 4 defines resident for treaty purposes as persons liable to tax by reason of domicile, residence, place of management, place of incorporation or similar criteria, excluding those taxable only on source income. For individuals dual resident under domestic laws, a hierarchical tie breaker applies: permanent home, centre of vital interests, habitual abode, nationality, and failing that mutual agreement by competent authorities. For non individual dual residents, competent authorities determine residence by mutual agreement considering place of incorporation, place of effective management and other relevant factors.

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