Tax residency tie-breaker rules determine residence by permanent home, centre of vital interests, habitual abode, then nationality. Residency under the DTAA is based on liability to tax under a Contracting State's laws, excluding persons taxed only on domestic-source income or capital. For individuals resident in both States, residency is resolved by sequential tie-breakers: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement of competent authorities. For persons other than individuals, dual residency is resolved by the place of effective management.