Resident status determination under the tax treaty applies tie breaker rules to resolve dual residency and governance by place of management. Definition of resident turns on liability to tax by domicile, residence, place of management or similar criteria and excludes persons taxed only on source income. For dual resident individuals, a cascade of tie breaker rules applies: permanent home, centre of vital interests, habitual abode, nationality, and failing these, mutual agreement by competent authorities; for dual resident entities, residency is determined by place of effective management or, if indeterminate, by mutual agreement.