(1) This Convention shall apply to persons who, for taxation purposes, are considered residents of one or both of the Contracting States.

(2) For the purposes of this Convention:

• (a) The term "resident of a Contracting State" means any person whose income or capital is subject to taxation in that State under its laws by reason of domicile, residence, place of management or establishment;
• (b) The term "resident of both Contracting States" shall mean any person deemed by each of the Contracting States to be a resident in the sense of the previous sub-paragraph, during the same period of time.

(3) When an individual is deemed to be a resident of both Contracting States, his status shall be determined as follows:

• (a) He 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 has no permanent home available to him in either Contracting State, he shall be deemed to be a resident of the Contracting State in which he has a habitual abode;
• (c) If he has a 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 each Contracting State considers him a national or if he is not a national of either of them, the competent authorities of the two Contracting States shall determine his residence in the manner stipulated in Article 20 of this Convention.

(4) When a person other than an individual is a resident of both Contracting States, it shall be deemed to be a resident of the Contracting State in which its place of effective management is situated.