FISCAL DOMICILE. 1. For the purposes of this Convention, the term "resident 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, place of management or any other criterion of a similar nature. 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 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 a 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 the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
FISCAL DOMICILE. 1. For the purposes of this Convention, the term "resident 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, place of management or any other criterion of a similar nature.
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 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 the Contracting State in which he has his centre of vital interests cannot be determined determined, or if he has 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 a 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 States, or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
FISCAL DOMICILE. 1. For the purposes of this Convention, the term "resident of a Contracting State" 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 or any other criterion of a similar nature. But this term does not include any person who is liable to tax in that 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 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 the Contracting State in which he has his centre of vital interests cannot be determined determined, or if he has 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 a an habitual abode;
(c) 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 he is a national of both Contracting States or of neither of them, the competent authorities of the Contracting States shall settle the question matter by mutual agreement.
Appears in 1 contract
FISCAL DOMICILE. 1. For the purposes of this Convention, the term "resident 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, place of management or any other 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 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 the Contracting State in which he has his centre of vital interests cannot be determined determined, or if he has 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 a 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 the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Samples: Convention to Avoid Double Taxation
FISCAL DOMICILE. 1. For the purposes of this ConventionAgreement, the term "" resident of a Contracting StateState " means any person who, under the law of that State, is liable to a resident of that State for the purposes of taxation therein by reason of his domicile, residence, place of management or any other criterion of a similar naturetherein.
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 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 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 Contracting State, he shall be deemed to be a resident of the Contracting State in which he has a an habitual abode;
(c) 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 he is a national of both the Contracting States or of neither of them, the competent authorities of the Contracting States shall settle determine the question by mutual agreement.
Appears in 1 contract
Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
FISCAL DOMICILE. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the law of that State, State is liable to taxation therein by reason of his domicile, residence, place of management or any other 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 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 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 determined, or if he has 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 a 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 the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
FISCAL DOMICILE. 1. For the purposes of this Convention, the term "resident 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, place of management or any other criterion of a similar nature.
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 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 the Contracting State in which he has his centre of or vital interests cannot be determined determined, or if he has 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 a 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 the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
FISCAL DOMICILE. 1. For the purposes of this Convention, the term "resident 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, place of management or any other criterion of a similar nature.
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 determined, or if he has 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 a 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 the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Samples: Double Tax Treaty (Dtt)
FISCAL DOMICILE. 1. For the purposes of this Convention, the term "resident 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, place of management or any other criterion of a similar nature.
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 (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 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 a 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 the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract