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of <h1>Determining Tax Residency: Permanent Home, Personal Ties, Citizenship, and Management Influence Under Treaty Rules</h1> A person is considered a resident of a Contracting State for tax purposes under this agreement if they are recognized as such by that state, excluding those taxed only on income from sources within the state. If an individual is deemed a resident of both Contracting States, residency is determined by the location of their permanent home or, if unavailable, by the state with closer personal and economic ties. Citizenship and habitual abode are also considered. For entities other than individuals, residency is determined by the location of their effective management.
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