Tax residence determination: tie breaker rules allocate dual residence by permanent home, centre of vital interests, habitual abode, nationality.

The Convention defines resident of a Contracting State as anyone liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on local-source income or local capital. For individuals who are residents of both States, a tie breaker hierarchy applies: permanent home; centre of vital interests; habitual abode; nationality; and, if unresolved, mutual agreement by competent authorities. Non individual dual residents are deemed residents of the State of their place of effective management.

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