Common use of FISCAL DOMICILE Clause in Contracts

FISCAL DOMICILE. 1. For the purpose of this Agreement, the term "resident of a Contracting State" means any person, whose income is subject to tax in that State, by reason of his domicile, residence, place of management or any other criterio of a similar nature. But this term does not include any person who is liable to tax in that Contracting State in respect only of income from sources therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his case shall be determined in accordance with the following rules: (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 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 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 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 theContracting States shall settle the question by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this AgreementConvention, the term "resident of a Contracting State" means any personperson who, whose income is subject to tax in under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management management, place of incorporation or any other criterio criterion of a similar nature. But this term does not include any person who is liable to tax in that Contracting State in respect only of income from sources in that State or capital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his case status shall be determined in accordance with the following rulesas follows: (a) He he shall be deemed to be a resident of the Contracting State in which he has a permanent home available to him. If ; 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 closest closer (centre of vital interests); (b) If if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has no not a 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 an habitual abode; (c) If 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 if he is a national of both Contracting States or of neither of them, the competent authorities of theContracting the Contracting States shall settle the question by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this AgreementConvention, the term "resident of a Contracting State" means any personperson who, whose income is subject to tax in under the law of that State, is liable to taxation therein by reason of his domicile, residence, place of management or any other criterio criterion of a similar nature. But this term does not include any person who is liable to tax in that Contracting State in respect only FBR, Government of income from sources therein.Pakistan 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his case status shall be determined in accordance with the following rules: (a) He 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 closest (hereinafter referred to as his "centre of vital interests"); (b) If if the Contracting State in which he has his centre of vital interests cannot be determined, determined or if he has no not a 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 an habitual abode; (c) If 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 if he is a national of both Contracting States or of neither of them, the competent authorities of theContracting the Contracting States shall settle the question by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this AgreementConvention, the term "resident of a Contracting State" means any personperson who, whose income is subject to tax in under the law of that State, is liable to taxation therein by reason of his domicile, residence, place of management or any other criterio criterion of a similar nature. But However, this term does not include any person who is liable to tax taxation in that Contracting State in respect only of income from sources in that State or capital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his case status shall be determined in accordance with the following rulesas follows: (a) He 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 closest closer (centre of vital interests); (b) If if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has no not a 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 an habitual abode; (c) If 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 if he is a national of both Contracting States or of neither of them, the competent authorities of theContracting the Contracting States shall settle the question by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this AgreementConvention, the term "resident of a Contracting State" means any personperson who, whose income is subject to tax in under the law of that State, is liable to taxation therein by reason of his domicile, residence, place of management or any other criterio criterion of a similar nature. But this term does not include any person who is liable to tax in that Contracting State in respect only of income from sources therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his case shall be determined in accordance with the following rules: (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 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 no not a 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 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 theContracting the Contracting States shall settle the question by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this AgreementConvention, the term "resident of a Contracting State" means any personperson who, whose income under the law of that State is subject liable to tax in that State, taxation therein by reason of his domicile, residence, place of management or any other criterio criterion of a similar nature. But this term does not include any person who is liable to tax in that Contracting State in respect only of income from sources thereintherein or capital situated in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his case status shall be determined in accordance with the following rulesas follows: (a) He 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 closest (centre of vital interests); (b) If if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has no not a 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 an habitual abode; (c) If 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 if he is a national of both Contracting States or of neither of them, the competent authorities of theContracting the Contracting States shall settle the question by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this Agreement, : (a) the term "resident of a Contracting Statethe Republic of China" means any person, whose income is subject to tax in that State, by reason of his domicile, residence, place of management or any other criterio of a similar nature. But this term does not include any person who is liable to a resident in accordance with the tax laws of China; and (b) the term "resident of the Repu blic of South Africa" means any individual who is ordinarily resident in that Contracting State South Africa and any legal person which has its place of management in respect only of income from sources thereinSouth Africa. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his case shall be determined in accordance with the following rules: (a) He he shall be deemed to be a resident of the Contracting State in which he has a permanent home domicile available to him. If he has a permanent home domicile 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 interests are closest closer (centre of vital interests); (b) If if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has no permanent home not a domicile available to him in either Contracting State, he shall be deemed to be a resident of the Contracting State in which he has an habitual abode; (c) If 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 if he is a national of both Contracting States or of neither of them, the competent authorities of theContracting the Contracting States shall settle the question by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this AgreementConvention, the term "resident of a Contracting State" means any personperson who, whose income is subject to tax in under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterio criterion of a similar nature. But this term does not include any person who is liable to tax in that Contracting State in respect only of income from sources in that State or capital situated therein. 2. Where Where, by reason of the provisions of paragraph 1 1, an individual is a resident of both Contracting States, then his case status shall be determined in accordance with the following rulesas follows: (a) He 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 closest closer (centre of vital interests); (b) If if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has no not a 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 an habitual abode; (c) If if he has an habitual abode in both Contracting States or in neither of them, then he shall be deemed to be a resident of the Contracting State of which he is a national; (d) If if he is a national of both Contracting States or of neither of them, the competent authorities of theContracting the Contracting States shall settle the question matter by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this Agreement, the term "resident of a Contracting State" means any personperson who, whose income is subject to tax in under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterio criterion of a similar nature. But this term does not include , and also includes that State and any person who is liable to tax in that Contracting State in respect only of income from sources thereinpolitical subpision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual inpidual is a resident of both Contracting States, then his case status shall be determined in accordance with the following rulesas follows: (a) He he shall be deemed to be a resident only of the Contracting State in which he has a permanent home available to him. If ; if he has a permanent home available to him in both Contracting States, he shall be deemed to be a resident only of the Contracting State with which his personal and economic relations are closest closer (centre of vital interests); (b) If if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has no not a permanent home available to him in either Contracting State, he shall be deemed to be a resident only of the Contracting State in which he has an habitual abode; (c) If if he has an habitual abode in both Contracting States or in neither of them, he shall be deemed to be a resident only of the Contracting State of which he is a national; (d) If he is a national of both Contracting States or of neither of themin any other case, the competent authorities of theContracting the Contracting States shall settle the question by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this AgreementConvention, the term "resident of a Contracting State" means any personperson who, whose income is subject to tax in under the laws of that State, is liable to taxation therein by reason of his domicile, residence, place of management or any other criterio criterion of a similar nature. But However, this term does shall not include any person who is liable to tax in that Contracting State only in respect only of income which he derives from sources thereintherein or in respect of capital which he possesses in that State. 2. Where Where, by reason of the provisions of paragraph 1 1, an individual is a resident of both Contracting States, then his case status shall be determined in accordance with the following rules: (a) He 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 in which his personal and economic relations are closest (centre of vital interests), including his economic interests, is situated; (b) If if the Contracting State in which he that person has his centre of vital interests cannot be determined, determined or if he has no not a permanent home available to him in either Contracting State, he shall be deemed to be a resident of the Contracting State State, in which he has an habitual abode; (c) If he if that person 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 if that person is a national of both Contracting States or of neither of them, the competent authorities of theContracting the Contracting States shall settle the question by mutual agreement. 3. Where, by reason of the provisions of paragraph 1, a person other than an individual is deemed to be 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.

FISCAL DOMICILE. 1. For the purpose purposes of this Agreement, the term "resident of a Contracting State" means any personperson who, whose income is subject to tax in under the laws of that State, is liable to taxation therein by reason of his domicile, residence, registered office, place of management or any other criterio criterion of a similar nature. But this term does not include any person who is liable to tax in that Contracting State in respect only of income from sources therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his case shall be determined in accordance with the following rules: (a) He 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 closest closer (centre of vital interests); (b) If if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has no not a 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 an habitual abode; (c) If 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 if he is a national of both Contracting States or of neither of them, the competent authorities of theContracting the Contracting States shall settle the question by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this Agreement, : (a) the term "resident of a Contracting Statethe Republic of China" means any person, whose income is subject to tax in that State, by reason of his domicile, residence, place of management or any other criterio of a similar nature. But this term does not include any person who is liable to a resident in accordance with the tax laws of China; and (b) the term "resident of the Republic of South Africa" means any individual who is ordinarily resident in that Contracting State South Africa and any legal person which has its place of management in respect only of income from sources thereinSouth Africa. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting Contraction States, then his case shall be determined in accordance with the following rules: (a) He he shall be deemed to be a resident of the Contracting State in which he has a permanent home domicile available to him. If he has a permanent home domicile 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 interests are closest closer (centre of vital interests); (b) If if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has no permanent home not a domicile available to him in either Contracting State, he shall be deemed to be a resident of the Contracting State in which he has an habitual abode; (c) If 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 if he is a national of both Contracting States or of neither of them, the competent authorities of theContracting the Contracting States shall settle the question by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this AgreementConvention, the term "resident of a Contracting State" means any personperson who, whose income is subject to tax in under the law of that State, is liable to taxation therein by reason of his domicile, residence, place of management or any other criterio criterion of a similar nature. But this term does not include any person who is liable to tax in that Contracting State in respect only of income from sources situated in that State or capital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his case status shall be determined in accordance with the following rulesas follows: (a) He 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 closest closer (centre of vital interests); (b) If if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has no not a 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 an habitual abode; (c) If 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 if he is a national of both Contracting States or of neither of them, the competent authorities of theContracting the Contracting States shall settle the question by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this Agreement, the term "" resident of a Contracting StateState " means any personperson who, whose income is subject to tax in under the law of that State, by reason is a resident of his domicile, residence, place that State for the purposes of management or any other criterio of a similar nature. But this term does not include any person who is liable to tax in that Contracting State in respect only of income from sources taxation therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both the Contracting States, then his case residential status for the purposes of this Agreement shall be determined in accordance with the following rules: (a) He 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 the Contracting States, he shall be deemed to be a resident of the Contracting State with which his personal and economic relations are closest closer (hereinafter referred to as his " centre of vital interestsinterests "); (b) If if the Contracting State in which he has his centre of vital interests cannot be determined, determined or if he has no not a 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 an habitual abode; (c) If if he has an habitual abode in both the 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 if he is a national of both the Contracting States or of neither of them, the competent authorities of theContracting the Contracting States shall settle determine the question by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this AgreementConvention, the term "resident of a Contracting State" means any personperson who, whose income is subject to tax in under the law of that State, is liable to taxation therein by reason of his domicile, residence, place of management or any other criterio criterion of a similar nature. But this term does not include any person who is liable to tax in that Contracting State in respect only of income from sources therein. 21. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, States then his this case shall be determined in accordance with the following rules: (a) He he shall be deemed to be a resident of the Contracting State in which he has a permanent home available to him. If ; 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 closest closer (centre of vital interests); (b) If if the Contracting State in which he has his centre of or vital interests cannot be determined, or if he has no not a 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 an habitual abode; (c) If 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 if he is a national of both Contracting States or of neither of them, the competent authorities of theContracting the Contracting States shall settle the question by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this AgreementConvention, the term "resident of a Contracting State" means any personperson who, whose income is subject to tax in under the law of that State, is liable to taxation therein by reason of his domicile, residence, place of management or any other criterio criterion of a similar nature. But this term does not include any person who is liable to tax in that Contracting State in respect only of income from sources therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his case status shall be determined in accordance with the following rulesas 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 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 no not a 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 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 theContracting the Contracting States shall settle the question by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this AgreementConvention, the term "resident of a Contracting State" means any personperson who, whose income is subject to tax in under the law of that State, is liable to taxation therein by reason of his domicile, residence, place of management or any other criterio criterion of a similar nature. But this term does not include any person who is liable to tax in that Contracting State in respect only of income from sources therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his this case shall be determined in accordance with the following rulesas follows: (a) He he shall be deemed to be a resident of the Contracting State in which he has a permanent home available to him. If ; if he has a permanent home available to him in both Contracting States, States he shall be deemed to be a resident of the Contracting State with which his personal family and economic relations are closest closer (centre of vital interests); (b) If if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has no not a 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 an habitual abode; (c) If 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 if he is a national of both Contracting States States, or of neither of them, the competent authorities of theContracting the Contracting States shall settle the question by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this AgreementConvention, the term "resident of a Contracting State" means any personperson who, whose income is subject to tax in under the law of that State, is liable to taxation therein by reason of his domicile, residence, place of management or any other criterio criterion of a similar nature. But this term does not include any person who is liable to tax in that Contracting State in respect only of income from sources thereinsituated in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his case status shall be determined in accordance with the following rulesas follows: (a) He 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 closest (centre of vital interests); (b) If if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has no not a 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 an habitual abode; (c) If 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 if he is a national of both Contracting States or of neither of them, the competent authorities of theContracting the Contracting States shall settle the question by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this Agreement, the term "" resident of a Contracting StateState " means any personperson who, whose income is subject to tax in under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterio criterion of a similar nature. But this term does not include any person who is liable to tax in that Contracting State in respect only of income from sources therein. 2. Where by reason of the provisions of paragraph 1 1, an individual is a resident of both Contracting States, contracting states then his case residential status for the purposes of this agreement shall be determined in accordance with the following rules:rules:--- (a) He a. he shall be deemed to be a resident of the Contracting State in which he has a permanent home available to him. If ; if he has a permanent home available to him in both Contracting States, States he shall be deemed to be a resident of the Contracting State with which his personal and economic relations are closest closer (hereinafter referred to as his " centre of vital interestsinterests "); (b) If b. if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has no does not have a 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 an habitual abode; (c) If 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 d. if he is a national of both Contracting States or of neither of them, the competent authorities of theContracting the Contracting States shall settle the question by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this Agreement, the term "resident of a Contracting State" means any personmeans, whose income is subject to tax in the provisions of paragraphs 2 and 3, any person who, under the laws of that Contracting State, is liable to taxation therein by reason of his domicile, residence, place of management or any other criterio criterion of a similar nature. But this term does not include any person who is liable to tax in that Contracting State in respect only of income from sources therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his case shall be determined in accordance with the following rules: (a) He 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 closest (hereinafter referred to as his centre of vital interests); (b) If if the Contracting State in which he has his centre of vital interests cannot be determined, or of if he has no not a 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 an habitual abode; (c) If 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 if he is a national of both Contracting States or of neither of them, the competent authorities of theContracting the Contracting States shall settle the question by mutual agreement.

FISCAL DOMICILE. 1. For the purpose purposes of this Agreement, the term "resident of a Contracting State" means any personperson who, whose income is subject to tax in under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management management, or any other criterio criterion of a similar nature. But this term does not include any person who is liable to tax in that Contracting State in respect only of income from sources thereinsituated in that State. 2. Where by reason of the provisions of paragraph 1 of this Article an individual is a resident of both Contracting States, then his case status shall be determined in accordance with the following rulesas follows: (a) He 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 closest closer (centre of vital interests); (b) If if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has no not a 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 an habitual abode; (c) If 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 if the status of both Contracting States or of neither of themresident cannot be determined according to sub-paragraphs (a) - (c), the competent authorities of theContracting the Contracting States shall settle the question by mutual agreement. 3. Where by reason of the provisions of paragraph 1 of this Article a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the State in which its place of effective management is situated.