(1) This Convention shall apply to persons residing in one or both of the Contracting States.

(2) In this Convention, the term "resident of a Contracting State" means a legal person, a company or any other organization which, for purposes of taxation, is considered to be a legal person in that State or is liable for taxation by reason of its place of effective management, as well as any individual who, for purposes of taxation, is considered to be a resident of that State.

(3) The term "resident of both Contracting States" means a person who, for purposes of taxation, is considered to be a resident of each of the Contracting States during the same period.

(4) Where by reason of the provisions of paragraphs (1) to (3) of this Article of this Convention, an individual shall be deemed to be a resident of both Contracting States, then his status shall be determined as follows:

• (a) such person shall be deemed to be a resident of the Contracting State in which he has a permanent home available to him. If he has a permanent home available to him in both Contracting States, he shall be deemed to be a resident of the Contracting State with which his personal and economic relations are closer (centre of vital interests);
• (b) if the Contracting State in which he has his centre of vital interests cannot be determined, or if he does not have a permanent home available to him in either Contracting 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 Contracting States or in neither of them, he shall be deemed to be a resident of the Contracting State of which he is a national;
• (d) if he is a national of both Contracting States or of neither of them, the competent authorities of the Contracting States shall settle the question of taxation by mutual agreement, in accordance with paragraph (3) of Article 20 of this Convention.

(5) Where, by reason of the provisions of paragraphs (1) to (3) of this Article, a person other than an individual is a resident of both Contracting States, he shall be deemed to be a resident of the Contracting State in which his place of effective management is situated.