Tax residency tie-breaker rules determine treaty residence by permanent home, centre of vital interests, habitual abode, then nationality.

The Article defines 'resident of a Contracting State' as any person liable to taxation therein by domicile, residence, place of management or similar criteria. For individuals resident in both States, treaty residence is determined by a hierarchy: permanent home; if in both States, centre of vital interests; if unclear or no permanent home, habitual abode; then nationality; unresolved cases are to be settled by mutual agreement. Persons other than individuals are deemed residents of the State where their place of effective management is situated.

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