Residency tie-breaker rules determine treaty residence for dual-residents using permanent home, centre of vital interests, habitual abode, nationality.

The treaty defines resident of a Contracting State by domestic tax liability and sets hierarchical tie breaker rules for dual resident individuals-permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement. For non individuals resident in both States, the competent authorities must endeavour to determine residence by reference to place of effective management, place of incorporation or other relevant factors, and absent agreement relief under the Agreement may be limited as agreed by those authorities.

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