Tax residence under treaty: tie breaker rules determine which state treats an individual as resident for taxation purposes. The term resident of a Contracting State means a person liable to tax there by reason of domicile, residence, place of management or similar criterion, excluding those taxable only on domestic-source income. For individuals resident in both States, tie breaker rules apply in order: permanent home, centre of vital interests, habitual abode, nationality, and mutual agreement. For non individuals resident in both States, residence is the place of effective management or, if indeterminate, is settled by mutual agreement of the competent authorities.