Tax residence tie breaker rules determine treaty residence and tax relief entitlement under the DTAA framework.

The Article defines resident status by domestic tax liability and sets sequential tie breaker rules for individuals: permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement by competent authorities. For persons other than individuals, competent authorities must endeavour to determine residence by mutual agreement considering place of effective management, place of incorporation or constitution and other relevant factors; absent agreement, treaty relief is only available to the extent agreed by those authorities.

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