Tax residence tie-breaker rules determine residency by permanent home, center of vital interests, habitual abode, nationality, or agreement. The Article defines resident of a Contracting State as persons liable to tax there by domicile, residence, place of registration, incorporation, management or similar criteria, excluding those taxable only on source income. Dual resident individuals are assigned residency by hierarchical tie breakers: permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement. Dual resident non individuals are resident only in the State of their place of effective management.