Where a person is a resident of both Contracting States, then his or her resident status shall be determined by the items in the order of the sequence stipulated in the provisions of the applicable DTA. The terms and criteria of the relevant items in the
1. The term “permanent home” means a place of residence arranged and retained by an individual, continuously available to him or her at all times.
2. The term “with which his or her personal and economic relations are closer (or centre of vital interests)” shall be determined by overall considering factors such as his or her family and social relations, his or her occupation, his or her political, cultural, or other activities, his or her place of business, and the place from which he or she administers his or her property, etc.
3. The term “habitual abode” shall be determined by comparing the length of time and frequency of the individual’s stays in the Contracting States.
4. The term “national” means any individual possessing nationality in accordance with the Nationality Act of a Contracting State.
5. The term “place of effective management” shall be determined by overall considering factors such as the location of key managerial personnel, and the place where they exercise management and control of a company or any other body of persons.