Tax residence tie breaker rules determine which State treats an individual or entity as resident for tax purposes. Resident is any person liable to tax in a Contracting State by reason of domicile, residence, place of management or similar criteria, excluding persons taxable only on local-source income; governments and their subdivisions are residents. For individuals resident in both States a tie breaker sequence applies: permanent home, centre of vital interests, habitual abode, nationality, and if unresolved, mutual agreement by competent authorities. For non-individuals resident in both States, residence is the State of the place of effective management.