Fiscal domicile tie breaker rules determine residency by permanent home, centre of vital interests, habitual abode, nationality.

The Convention defines resident status by domestic tax criteria and provides tie breaker rules for dual resident individuals: availability of a permanent home, centre of vital interests if homes exist in both States, habitual abode if the centre of vital interests is indeterminate or no permanent home exists, nationality if habitual abode is inconclusive, and mutual agreement of competent authorities as a last resort. For persons other than individuals, dual residency is resolved by the location of the place of effective management.

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