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(1) For the purposes of this Agreement, the term "res- ident of a Contracting State” means any person who, under the law of that State, is liable to taxation therein by reason of his domicile, residence, registration, in- corporation, seat (Sitz), place of management or any other criterion of a similar nature.
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(2) If by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, this case shall be determined in accordance with the following rules: a) He shall be deemed to be a resident of the Contract- ing 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 rela:ions are closest (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 not a permanent home available to him in either Con- tracting State, he shall be deemed to be a resident of the Contracting State in which he has an habitual abode: 9 It 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; 4) 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 by mutual agreement.
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(3) If by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement.