Tax residency rules determine treaty residence and tie-breaker criteria for dual residents under DTAA provision.

The DTAA defines a "resident of a Contracting State" as any person liable to tax there by domicile, residence, place of management, place of incorporation or similar criteria, excluding those taxable only on in-state income or capital. For dual-resident individuals the treaty sets tie-breaker rules: permanent home, centre of vital interests, habitual abode, nationality, and failing those the competent authorities decide. For non-individual dual residents residence is the State of nationality, with mutual agreement procedures where nationality is shared or absent and no treaty relief if no agreement is reached.

---

---

---