Resident of a territory: tie breaker rules determine which jurisdiction treats a person as resident for treaty taxation purposes.

The provision defines resident of a territory as any person liable to tax therein by reason of domicile, residence, place of incorporation, place of management or similar criteria, and excludes persons taxable only on territory sourced income (with a narrow exception for certain individuals). For individuals who are residents of both territories, residence is determined by permanent home, then centre of vital interests, then habitual abode, with unresolved cases settled by mutual agreement. For non individuals resident in both territories, residence is determined by place of effective management, failing which competent authorities reach mutual agreement.

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