Residence tie breaker rules allocate tax residence by permanent home, centre of vital interests, habitual abode, nationality, or mutual agreement. The treaty defines 'resident' as any person liable to tax in a Contracting State by domicile, residence, place of management or similar criteria, excluding those taxable only on source income. Dual residency for individuals is resolved by tie breakers: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement between competent authorities. Dual residency for entities is resolved by the location of the place of effective management, or otherwise by mutual agreement of the competent authorities.