Residence. 1. Except as provided in paragraphs 2 and 3 of this Article, the term “resident of a Contracting State” means, for the purposes of this Convention, any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or of profits attributable to a permanent establishment in that State.
Appears in 4 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Residence. 1. Except as provided in paragraphs 2 and 3 of this Article, the term “resident of a Contracting State” means, for For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of managementCitizenship, place of incorporation, or any other criterion of a similar nature. This termHowever, however, 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 of profits attributable to a permanent establishment in that Stateproperty situated therein.
Appears in 3 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Residence. 1. Except as provided in paragraphs 2 and 3 For the purposes of this ArticleAgreement, the term “resident of a Contracting State” means, for the purposes of this Convention, means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, incorporation (registration) or any other criterion of a similar nature, and also includes that State and any statutory body or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or of profits attributable to a permanent establishment in that State.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, Income Tax Agreement, Double Taxation Avoidance Agreement
Residence. 1. Except as provided in paragraphs 2 and 3 of this Article, the term “resident of a Contracting State” means, for For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, or any other criterion of a similar nature. This termHowever, however, this term does not include any person who that is liable to tax in that State in respect only of income from sources in that State or of profits attributable to a permanent establishment in that State.
Appears in 3 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Residence. (1. Except as provided in paragraphs 2 and 3 ) For the purposes of this ArticleConvention, the term “resident of a Contracting State” means, for the purposes of this Convention, means any person who, under the laws of that State, is liable to tax therein by reason of his that person’s domicile, residence, citizenship, place of management, place of incorporation, incorporation or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in and also includes that State in respect only of income from sources in that State and any political subdivision or of profits attributable to a permanent establishment in that Statelocal authority thereof.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Residence. 1. Except as provided in paragraphs 2 and 3 For the purposes of this ArticleConvention, the term “resident of a Contracting State” means, for the purposes of this Convention, means any person who, under the laws of that State, is liable to tax therein by reason of his that person’s domicile, residence, citizenship, place of management, place of incorporation, incorporation or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in and also includes that State in respect only of income from sources in that State and any political subdivision or of profits attributable to a permanent establishment in that Statelocal authority thereof.
Appears in 2 contracts
Samples: Double Taxation Agreement, Convention for the Avoidance of Double Taxation
Residence. (1. Except as provided in paragraphs 2 and 3 ) For the purposes of this ArticleConvention, the term “resident of a Contracting State” means, for the purposes of this Convention, means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, registration or any other criterion of a similar nature. This term, however, ; the term does not include any person who is liable to tax in that Contracting State in respect only of if he derives income or capital gains from sources in that State or of profits attributable to a permanent establishment in that Statetherein.
Appears in 1 contract
Residence. 1. Except as provided in paragraphs 2 and 3 For the purposes of this ArticleConvention, the term “resident of a Contracting State” means, for the purposes of this Convention, means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, or any other criterion of a similar nature. This term, provided, however, that 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 of profits attributable to a permanent establishment in that State.
Appears in 1 contract
Residence. 1. Except as provided in paragraphs 2 and 3 For the purposes of this ArticleAgreement, the term “resident of a Contracting State” means, for the purposes of this Convention, means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, management or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or of profits attributable to a permanent establishment in that State.
Appears in 1 contract
Residence. 1. Except as provided in paragraphs 2 and 3 For the purposes of this ArticleAgreement, the term “"resident of a Contracting State” means, for the purposes of this Convention, " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, incorporation (registration) or any other criterion of a similar nature, and also includes that State and any statutory body or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or of profits attributable to a permanent establishment in that State.
Appears in 1 contract
Residence. 1. Except as provided in paragraphs 2 and 3 For the purposes of this ArticleAgreement, the term “"resident of a Contracting State” means, for the purposes of this Convention, " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, incorporation or any other criterion of a similar nature. This term, however, The 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 of profits attributable to a permanent establishment in that State.
Appears in 1 contract
Samples: Income Tax Treaty
Residence. 1. Except as provided in paragraphs 2 and 3 of this Article, the term “resident of a Contracting State” means, for the purposes of this Convention, any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or of profits attributable to a permanent establishment in that State.of
Appears in 1 contract
Residence. 1. Except as provided in paragraphs 2 and 3 For the purpose of this ArticleConvention, the term “"resident of a Contracting State” means, for the purposes of this Convention, " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, management or any other criterion of a similar nature. This term, however, 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 of profits attributable to a permanent establishment in that Statecapital situated therein.
Appears in 1 contract
Samples: Double Taxation Convention
Residence. 1. Except as provided in paragraphs 2 and 3 of this Article, the term “resident of a Contracting State” means, for For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, incorporation (registration) or any other criterion of a similar nature, and also includes that State, any political subdivision and any statutory body or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or of profits attributable to a permanent establishment in that State.
Appears in 1 contract
Residence. 1. Except as provided in paragraphs 2 and 3 For the purposes of this ArticleConvention, the term “resident of a Contracting State” means, for the purposes of this Convention, means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, or any other criterion of a similar nature. This term, provided, however, that 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 of profits attributable to a permanent establishment in that State.
Appears in 1 contract
Residence. 1. Except as provided in paragraphs 2 and 3 For the purposes of this ArticleAgreement, the term “"resident of a Contracting State” means, for the purposes of this Convention, " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, effective management or any other criterion of a similar nature. This termHowever, however, the 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 of profits attributable to a permanent establishment in that State.
Appears in 1 contract
Residence. 1. Except as provided in paragraphs 2 and 3 For the purposes of this ArticleConvention, the term “resident of a Contracting State” means, for the purposes of this Convention, means any person who, under the laws law of that Contracting State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, management or any other criterion of a similar nature. This term, however, 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 of profits attributable to a permanent establishment in that State.
Appears in 1 contract
Residence. 1. Except as provided in paragraphs 2 and 3 For the purposes of this ArticleAgreement, the term “resident of a Contracting State” means, for the purposes of this Convention, means any person who, under who is a resident of that State in accordance with the taxation laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or of profits attributable to a permanent establishment in that State.
Appears in 1 contract
Samples: Income Tax Agreement
Residence. 1. Except as provided in paragraphs 2 and 3 For the purposes of this ArticleConvention, the term “resident of a Contracting State” means, for the purposes of this Convention, means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, or any other criterion of a similar nature. This term, provided, however, that 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 of profits attributable to a permanent establishment in that State.
Appears in 1 contract
Samples: Income Tax Convention
Residence. 1. Except as provided in paragraphs 2 and 3 For the purposes of this ArticleAgreement, the term “"resident of a Contracting State” means, for the purposes of this Convention, " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, incorporation (registration) or any other criterion of a similar nature, and also includes that State, and any political subdivision, statutory body or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or of profits attributable to a permanent establishment in that State.
Appears in 1 contract
Residence. 1. Except as provided in paragraphs 2 and 3 For the purposes of this ArticleAgreement, the term “resident of a Contracting State” means, for the purposes of this Convention, means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, incorporation (registration) or any other criterion of a similar nature. This termA Contracting State itself, howeverand a local authority and a statutory body thereof, shall be deemed to be a resident of that State. The 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 of profits attributable to a permanent establishment in that State.
Appears in 1 contract
Samples: Income Tax Agreement
Residence. (1. Except as provided in paragraphs 2 and 3 ) For the purposes of this ArticleConvention, the term “resident of a Contracting State” means, for the purposes of this Convention, means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or of profits attributable to a permanent establishment in that Statecapital situated therein.
Appears in 1 contract
Samples: Income and Capital Tax Convention
Residence. (1. Except as provided in paragraphs 2 and 3 ) For the purposes of this ArticleConvention, the term “resident of a Contracting State” means, for the purposes of this Convention, means any person who, under the laws law of that State, is liable to tax taxation therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, management or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or of profits attributable to a permanent establishment in that State.
Appears in 1 contract
Samples: Income and Capital Tax Convention
Residence. 1. Except as provided in paragraphs 2 and 3 For the purposes of this ArticleAgreement, the term “resident of a Contracting State” means, for the purposes of this Convention, means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, incorporation (registration) or any other criterion of a similar nature, and also includes that State, and any political subdivision, statutory body or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or of profits attributable to a permanent establishment in that State.
Appears in 1 contract
Samples: Income Tax Agreement
Residence. 1. Except as provided in paragraphs 2 and 3 For the purposes of this ArticleAgreement, the term “resident of a Contracting State” means, for the purposes of this Convention, means any person who, under the laws of that State, is liable to tax therein by reason of his or her domicile, residence, citizenship, place of management, place of incorporation, incorporation (registration) or any other criterion of a similar nature, and also includes that State, its Länder and any political subdivision or local authority of a Contracting State or a Land, and any corporation under public law. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or of profits attributable to a permanent establishment in that State.
Appears in 1 contract
Residence. 1. Except as provided in paragraphs 2 and 3 For the purposes of this ArticleConvention, the term “resident of a Contracting State” means, for the purposes of this Convention, means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, or any other criterion of a similar nature. This term, provided, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or of profits attributable to a permanent establishment in that State.that
Appears in 1 contract
Residence. 1. Except as provided in paragraphs 2 and 3 For the purposes of this ArticleAgreement, the term “resident of a Contracting State” means, for the purposes of this Convention, means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, management or any other criterion of a similar nature. This termHowever, however, the 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 of profits attributable to a permanent establishment in that State.
Appears in 1 contract
Residence. 1. Except as provided in paragraphs 2 and 3 For the purposes of this ArticleAgreement, the term “"resident of a Contracting State” means, for the purposes of this Convention, " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, management or any other criterion of a similar nature. This termHowever, however, the 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 of profits attributable to a permanent establishment in that State.
Appears in 1 contract
Samples: Income Tax Agreement