Tax residence determination under DTAA: tie breaker rules allocate residency by permanent home, centre of vital interests, habitual abode, nationality. The Article defines a resident as a person liable to tax by reason of domicile, residence, place of management or similar criteria, excluding those taxed only on in state source income. For dual resident individuals, residency is resolved by a sequence: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement. For dual resident non individuals, residency is determined by the place of effective management.