Residence tie breaker rules determine tax residency by permanent home, centre of vital interests, habitual abode, nationality, or mutual agreement.

The Agreement defines resident of a Contracting State as persons liable to tax there by domicile, residence, place of management, place of incorporation or similar criteria, excluding those taxable there only on source income. For dual resident individuals, residency is determined by permanent home, then by centre of vital interests, habitual abode, nationality, and finally mutual agreement. For non individual dual residents, competent authorities should resolve residency by reference to place of effective management or other relevant criteria; absent agreement, such persons are not treated as residents of either State for Agreement benefits.

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