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of <h1>Definition of 'Resident of a Contracting State' for Taxation: Criteria and Resolution for Dual Residency Disputes</h1> The term 'resident of a Contracting State' refers to any person subject to taxation in that state due to domicile, residence, or similar criteria, excluding those taxed solely on income from local sources. If an individual is considered a resident of both states, residency is determined by the location of a permanent home, center of vital interests, habitual abode, or nationality. For non-individuals deemed residents of both states, resolution is sought through mutual agreement between the states' authorities, and without agreement, such entities are not considered residents for treaty benefits.
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