Resident status tie-breaker rules determine which state taxes an individual based on permanent home and centre of vital interests.

The Convention defines resident of a Contracting State as any person liable to tax there under domestic law, excluding those taxed only on source income or in state capital. For individuals resident in both States a tie breaker sequence determines residence: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement. For non individuals resident in both States, residence is determined by the place of effective management, with unresolved cases referred to mutual agreement between competent authorities.

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