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          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.

          Provisions expressly mentioned in the judgment/order text.

          <h1>Resident tie-breaker rules determine treaty residency based on permanent home and centre of vital interests.</h1> The Agreement defines resident status by domestic taxation law and applies a sequential tie breaker for individuals: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement if earlier tests fail; for non individuals residency is determined by the place of effective management.

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