Summary of the discussion at the joint IFA/OECD seminar at the 2004 IFA congress in Vienna on the place of effective management as a residence tie-breaker. The seminar considered the meaning of "place of effective management" in Art. 4(3) of the OECD Model as the tie-breaker for dual resident persons other than individuals. In this context, the panel looked at four cases involving the place of effective management : the directors' meetings, the parent company's involvement, the peripatetic management, and the one-person company.