Residence determination rules: tie breaker criteria decide which State's taxation applies when an individual or entity is resident in both States.

Article 4 defines resident as a person liable to tax by reason of domicile, residence, place of management or similar criteria. Where an individual is resident of both States, tie breaker rules apply in sequence: permanent home; centre of vital interests if homes exist in both States; habitual abode; nationality; and, failing resolution, settlement by mutual agreement. For non individuals resident in both States, residence is the State of the place of effective management, with unresolved cases referred to the competent authorities for mutual agreement.

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