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of <h1>Defining Residency: Criteria for Determining Tax Residency Under Dual State Agreements, Including Permanent Home and Effective Management.</h1> The term 'resident of a Contracting State' refers to any person liable to tax in that state due to domicile, residence, or similar criteria, excluding those taxed solely on income from sources within that state. If an individual is a resident of both Contracting States, residency is determined by the location of a permanent home, center of vital interests, habitual abode, or nationality. For non-individuals, residency is based on the place of effective management. If these criteria are inconclusive, the competent authorities of the Contracting States will resolve the matter through mutual agreement.
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