Treaty residence rules define dual residency, tie-breakers, and entity residence under the Brazil tax convention. Defines resident of a Contracting State by reference to liability to tax on the basis of domicile, residence, incorporation, management, or similar criteria, while excluding persons taxable only on source income. Dual residence of individuals is resolved through permanent home, centre of vital interests, habitual abode, nationality, and mutual agreement. Dual residence of entities is determined by the place of effective management, or otherwise by mutual agreement, with treaty relief limited absent such agreement.