1. For the purposes of this Agreement, the term “resident of a Contracting  State” means any person who, under the laws of that State, is liable to tax therein by  reason of his domicile, residence, place of management or any other criterion of a  similar nature. But this term does not include any person who is liable to tax in that  State in respect only of income from sources in that State or capital situated therein. 

2. Where by reason of the provisions of paragraph 1 an individual is a resident  of both Contracting States, then his status shall be determined as follows: 

a) he shall be deemed to be a resident of the State in which he has a  permanent home available to him; if he has a permanent home available to him in  both States, he shall be deemed to be a resident of the State with which his personal  and economic relations are closer (centre of vital interests); 

b) if the State in which he has his centre of vital interests cannot be  determined, or if he has not a permanent home available to him in either State, he  shall be deemed to be a resident of the State in which he has an habitual abode; 

c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident of the State of which he is a national; 

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 management is situated.