FISCAL DOMICILE. 1 For the purposes of this Convention, the term “resident of a Contracting State” means, subject to the provisions of paragraphs (2) and (3) of this Article, any person who, under the law of that State, is liable to taxation therein by reason of his domicile, residence, place of management, place of incorporation, or any other criterion of a similar nature.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
FISCAL DOMICILE. 1 1. For the purposes of this ConventionAgreement, the term “resident of a Contracting State” means, subject to the provisions of paragraphs (2) and (3) of this Article, means any person who, under the law laws of that State, is liable to taxation tax therein by reason of his domicile, residence, place of managementincorporation, place of incorporation, management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof.
Appears in 2 contracts
Samples: Agreement for the Elimination of Double Taxation, Agreement for the Elimination of Double Taxation
FISCAL DOMICILE. 1 1. For the purposes of this Convention, the term “"resident of a Contracting State” means, subject to the provisions of paragraphs (2) and (3) of this Article, " means any person who, under the law of that State, is liable to taxation therein by reason of his domicile, residence, place of managementhead or main office, place of incorporation, management or any other criterion of a similar nature.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
FISCAL DOMICILE. 1 1. For the purposes of this Convention, the term “"resident of a Contracting State” means, subject to the provisions of paragraphs (2) and (3) of this Article, " means any person who, under the law laws of that State, is liable to taxation tax therein by reason of his domicile, residence, place of management, place of incorporation, management or any other criterion of a similar nature.
Appears in 2 contracts
Samples: Double Taxation Agreement, Convention for the Avoidance of Double Taxation
FISCAL DOMICILE. 1 For the purposes of this Convention, the term “"resident of a Contracting State” " means, subject to the provisions of paragraphs (2) 2 and (3) 3 of this Article, any person who, under the law of that State, is liable to taxation therein there by reason of his domicile, residence, place of management, place of incorporation, management or any other criterion of a similar nature. The terms "resident of the United Kingdom" and "resident of Romania" shall be construed accordingly.
Appears in 1 contract
Samples: Double Taxation Convention
FISCAL DOMICILE. 1 1. For the purposes of this ConventionAgreement, the term “"resident of a Contracting State” means, subject to the provisions of paragraphs (2) and (3) of this Article, " means any person who, under the law laws of that State, is liable to taxation tax therein by reason of his domicile, residence, place of management, place of incorporation, management or any other criterion of a similar nature.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
FISCAL DOMICILE. 1 For the purposes of this ConventionAgreement, the term “"resident of a Contracting State” means, subject to the provisions of paragraphs (2) and (3) of this Article, " means any person who, under the law of that State, is liable to taxation therein by reason of his domicile, residence, place of management, place of incorporation, management or any other criterion of a similar nature.. Where by reason of the provisions of paragraph 1 an inpidual is a resident of both Contracting States, then his case shall be determined in accordance with the following rules:
Appears in 1 contract
Samples: Double Taxation Agreement