Tax residency tie breaker: sequential tests determine which State is resident for treaty purposes, affecting cross border taxation. Article 4 defines resident of a Contracting State: India uses domestic criteria (domicile, residence, place of management, etc.) excluding persons taxable only on India-source income; South Africa covers individuals ordinarily resident and persons with place of effective management there. Dual resident individuals are subject to a sequential tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and failing those, competent authority mutual agreement. Dual residency for non individuals is resolved by place of effective management or, if indeterminate, by mutual agreement of competent authorities.