Resident

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.... similar nature, and also includes that Contracting State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that Contracting State in respect only of income from sources in that Contracting State or capital situated therein.] 2.  Where by reason of the provisions of paragraph 1, an individual is a resident o....

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.... (d) if he is a national of both States or of neither of them the competent authorities of the Contracting States shall settle the question by mutual agreement. 3.  Where by reason of the provisions of paragraph 1, a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the State in which its place of effective ma....