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of <h1>Tax Residency Defined: Criteria for Individuals and Entities under Contracting States' Agreement</h1> The term 'resident of a Contracting State' refers to any person liable to tax in that state due to domicile, residence, place of management, incorporation, or similar criteria, excluding those taxed only on income from sources within that state. For individuals considered residents of both states, residency is determined by permanent home availability, center of vital interests, habitual abode, or nationality. If unresolved, authorities will mutually agree. For non-individuals, residency is determined by the place of effective management, with mutual agreement sought if indeterminate.
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