Tax residency tie-breaker rules determine which State's residency applies based on permanent home, centre of vital interests, habitual abode. The Convention defines resident as any person liable to tax in a Contracting State by reason of domicile, residence, place of management or similar criteria, excluding those taxed only on local source income or capital. For dual resident individuals a tie breaker sequence applies: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement of competent authorities. For dual resident entities the place of effective management determines residency, with unresolved cases referred to the competent authorities for mutual agreement.