Tax residence tie breaker rules determine treaty residency and apply personal and management tests for dual residents. The Article defines resident of a Contracting State as a person liable to tax there by domicile, residence, place of incorporation, place of management or similar criterion, excluding persons taxable only on in state source income. For dual resident individuals it prescribes a hierarchical tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and referral to competent authorities if unresolved. For non individuals it attributes residence to the State of the entity's place of effective management, with unresolved cases to be settled by mutual agreement of the competent authorities.