Residence tie breaker: treaty residence determined by permanent home, centre of vital interests, habitual abode, nationality. The provision defines resident of a Contracting State as any person liable to taxation therein by reason of domicile, residence, place of incorporation, place of management or similar criteria. For individuals deemed residents of both Contracting States, treaty residence is resolved by: availability of a permanent home; the State of the individual's centre of vital interests; habitual abode; nationality; or mutual agreement of competent authorities. For non individuals, residence in cases of dual residency is determined by the place of effective management.