Resident status determines tax residency using permanent home, centre of vital interests, habitual abode and nationality tie breakers. The Article defines resident of a Contracting State as a person liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding those taxed only on source income or local capital. For dual resident individuals, residence is resolved by tie breakers in sequence: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement of competent authorities. Dual residence for non individuals is resolved by the location of the entity's place of effective management.
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Resident status determines tax residency using permanent home, centre of vital interests, habitual abode and nationality tie breakers.
The Article defines resident of a Contracting State as a person liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding those taxed only on source income or local capital. For dual resident individuals, residence is resolved by tie breakers in sequence: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement of competent authorities. Dual residence for non individuals is resolved by the location of the entity's place of effective management.
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