Tax residency rules determine which State an individual or entity is treated as resident for treaty taxation purposes.

Defines resident for the Convention as any person liable to tax in a Contracting State by reason of domicile, residence, place of incorporation, place of management or similar criteria, excluding persons taxable only on income from sources or capital within that State. Dual-resident individuals are allocated residency by permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement, while dual-resident non-individuals are allocated by place of effective management or mutual agreement.

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