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When we talk about the tie-breaker rule in the OECD model tax treaty, one of the key factors that comes into play is the concept of habitual abode. This simply refers to the amount of time an individual spends in each country. In order to determine this, we consider various aspects such as where the taxpayer has a permanent residence, their personal and economic connections, and their center of vital interests. This rule is crucial in determining which country has the primary right to tax an individual's income.
