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Common use of RESIDENT Clause in Contracts

RESIDENT. 1. 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, place of management 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 capital situated therein.

Appears in 21 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. 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 capital situated thereinState.

Appears in 21 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement

RESIDENT. 1. 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, place of management 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 capital situated therein.

Appears in 20 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Elimination of Double Taxation

RESIDENT. 1. 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, place of management 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 capital situated thereinState.

Appears in 18 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation

RESIDENT. 1. 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, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. 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 capital situated therein.

Appears in 13 contracts

Samples: Convention for the Avoidance of Double Taxation, Double Taxation Agreement, Convention for the Avoidance of Double Taxation

RESIDENT. 1. For the purposes of this ConventionAgreement, 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, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or subdivision, local authority or statutory body 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 capital situated therein.

Appears in 11 contracts

Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement

RESIDENT. 1. 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, place of management management, place of 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 capital situated therein.

Appears in 10 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management 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 capital situated thereinState.

Appears in 9 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management management, place of 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 or capital gains from sources in that State or capital situated thereinState.

Appears in 9 contracts

Samples: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation

RESIDENT. 1. For the purposes of this ConventionAgreement, 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, place of management 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 capital situated thereinState.

Appears in 8 contracts

Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Agreement, Double Taxation Agreement

RESIDENT. 1. 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, place of management management, place of 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, 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.

Appears in 6 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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 residence, domicile, residencecitizenship, place of management management, place of incorporation, or any other criterion of a similar nature. 2. a) However, and also includes that State and any political subdivision or local authority thereof. This term, however, the term "resident of a Contracting State" 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.State;

Appears in 6 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. For the purposes of this ConventionAgreement, 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, place of management 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 capital situated thereinState.

Appears in 6 contracts

Samples: Agreement for the Elimination of Double Taxation, Agreement for the Elimination of Double Taxation, Agreement for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management or any other criterion of a similar nature, and also includes that State and any political administrative-territorial 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 capital situated therein.

Appears in 5 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. For the purposes of this ConventionAgreement, 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, place of management or any other criterion of a similar nature, 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 capital situated thereinState.

Appears in 5 contracts

Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Double Taxation Agreement

RESIDENT. (1. ) For the purposes of this ConventionAgreement, 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, place of management management, place of 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 or capital from sources in that State or capital situated thereinState.

Appears in 5 contracts

Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Agreement

RESIDENT. 1. For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws of that Contracting State, is liable to tax therein by reason of his domicile, residence, place of head or main office, place of incorporation, place of management or any other criterion of a similar nature, and also includes that Contracting State and any political subdivision or local authority thereof. This term, however, 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 thereinContracting State.

Appears in 5 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation

RESIDENT. 1. 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, place of management management, place of 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 capital situated thereinState.

Appears in 5 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. 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 capital situated thereinState.

Appears in 5 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement

RESIDENT. 1. 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 that person’s domicile, residence, place of management 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 capital situated therein.

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

RESIDENT. 1. 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, place of management management, place of 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 capital situated thereinState.

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

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State” means " means: (a) any person who, 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 criterion of a similar nature, and also includes ; (b) the Government of that State and any or a political subdivision or local authority thereofthereof or any agency or instrumentality of any such government, subdivision or authority. 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 capital situated thereinState.

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

RESIDENT. 1. 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, place of incorporation, place of management 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 capital situated therein.

Appears in 4 contracts

Samples: Agreement for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Income and Capital Tax Convention

RESIDENT. 1. For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws of that State, State is liable to tax therein in that State by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political administrative 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 capital situated thereinState.

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

RESIDENT. 1. For the purposes of this ConventionAgreement, 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, place of management management, place of 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 or capital gains from sources in that State or capital situated thereinState.

Appears in 3 contracts

Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement

RESIDENT. 1. For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws law of that State, State is liable to tax therein taxes in that State by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political administrative subdivision or local authority authorities 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 capital 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

RESIDENT. 1. 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, place of effective management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. 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 capital situated therein.

Appears in 3 contracts

Samples: Income and Capital Tax Convention, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management management, place of 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 capital situated thereinState.

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

RESIDENT. 1. For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws law of that State, State is liable to tax therein taxes in that State by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State States and any political administrative subdivision or local authority authorities 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 capital situated thereinState.

Appears in 2 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management 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 capital situated thereinState.

Appears in 2 contracts

Samples: Income Tax Convention, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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 management, place of 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 capital situated thereintherein or of profits attributable to a permanent establishment in that State.

Appears in 2 contracts

Samples: Convention for the Avoidance of Double Taxation, Double Taxation Convention

RESIDENT. (1. ) For the purposes purpose 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, place of management head or main office, place of management, place of registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. 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 capital situated thereinState.

Appears in 2 contracts

Samples: Double Taxation Agreement, Double Taxation Agreement

RESIDENT. 1. 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, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereofthereof as well as a recognised pension fund of that State. 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 capital situated therein.

Appears in 2 contracts

Samples: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation

RESIDENT. 1. 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, place of registration, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision subdivision, administrative-territorial unit 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 capital situated thereinState.

Appears in 2 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of incorporation, place of management 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 capital situated thereinState.

Appears in 2 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of incorporation, place of management or any other criterion of a similar nature, 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 capital situated therein.

Appears in 2 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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 that person’s domicile, residence, place of management management, place of 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 capital situated therein.

Appears in 2 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. (1. ) 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, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. 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 capital situated therein.

Appears in 2 contracts

Samples: Convention for the Avoidance of Double Taxation, Income and Capital Tax Convention

RESIDENT. 1. 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, place of management management, place of 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 or capital gains from sources in that State or capital situated therein.

Appears in 2 contracts

Samples: Double Taxation Convention, Income and Capital Tax Convention

RESIDENT. 1. 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, place of incorporation, place of management 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 capital situated therein.

Appears in 2 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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 as a resident of that State or is liable to tax by reason of his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereofthereof as well as a recognised pension fund of that State. 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 capital situated thereinState.

Appears in 2 contracts

Samples: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation

RESIDENT. 1. 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, place of management management, place of 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, 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 thereinState.

Appears in 2 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. (1. ) 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, place of incorporation or establishment, place of management 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 capital situated therein.

Appears in 2 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management registration, place of 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 capital situated therein.

Appears in 2 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management or any other criterion of a similar nature, and also includes that State and any governmental body or agency, 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 capital situated therein.

Appears in 2 contracts

Samples: Convention for the Elimination of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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 that person’s domicile, residence, place of management management, place of 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 capital situated therein.

Appears in 2 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of incorporation, place of management or any other criterion of a similar nature, and also includes include that State and any political administrative 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 capital situated therein.

Appears in 2 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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 that person’s domicile, residence, place of management 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 capital situated therein.

Appears in 2 contracts

Samples: Double Taxation Agreement, Convention for the Avoidance of Double Taxation

RESIDENT. (1. ) For the purposes of this ConventionAgreement, 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, place of management or any other criterion of a similar nature, and also includes that State State, a Land 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 capital situated therein.

Appears in 2 contracts

Samples: Agreement for the Avoidance of Double Taxation, Income and Capital Tax Agreement

RESIDENT. 1. 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, place of management management, place of incorporation, place of registered office or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof, as well as a recognised pension fund of that State. This term, however, does not include any person who is liable to tax in that State in respect only of income or capital gains from sources in that State or capital situated therein.

Appears in 2 contracts

Samples: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation

RESIDENT. 1. 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, place of management or any other criterion of a similar nature, nature and also includes that State and any political or administrative 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 capital situated therein.

Appears in 2 contracts

Samples: Income and Capital Tax Convention, Income and Capital Tax Convention

RESIDENT. 1. 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 as a resident of his domicile, residence, place of management or any other criterion of a similar naturethat State, and also includes the Government of 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 capital situated thereinState.

Appears in 2 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws law of that State, is liable to tax therein by reason of his domicile, residence, place of management management, or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. 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 capital situated therein.

Appears in 2 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision administrative-territorial subdivisions or local authority thereofauthority. 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 capital property situated therein.

Appears in 2 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws of that Contracting State, is liable to tax therein by reason of his domicile, residence, place of incorporation or organisation, place of head or main office, place of management or any other criterion of a similar nature, and also includes that Contracting State and any political subdivision or local authority thereofthereof as well as a recognised pension fund of that Contracting State. This term, however, 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 thereinContracting State.

Appears in 2 contracts

Samples: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation

RESIDENT. 1. 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, place of management management, place of incorporation or any other criterion of a similar nature, and also includes that State and any governmental body or agency, 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 or capital gains from sources in that State or capital situated thereinState.

Appears in 2 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management management, place of 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 capital situated therein.

Appears in 2 contracts

Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws law of that State, is liable to tax therein by reason of his domicile, residence, place of management management, place of 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, But this term does not include any person who is liable to tax in that State in respect only of income from sources situated in that State or capital situated thereinState.

Appears in 1 contract

Samples: Income and Capital Tax Treaty

RESIDENT. 1. 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, place of management management, place of registration 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 capital situated therein.political

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management head or main office, place of management, place of 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 capital situated thereinState.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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 income tax therein by reason of his domicile, residence, place of incorporation, place of management 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 capital situated therein.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management management, place of incorporation, or any other criterion of a similar nature, 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 capital situated therein.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management 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 capital situated therein.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management management, place of incorporation or any other criterion of a similar nature, and . The term shall also includes include the Government of that Contracting State and any political subdivision or a local authority thereof. 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 capital situated therein.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management or any other criterion of a similar naturena- ture, 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 capital situated therein.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management 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 derived from sources in that State or capital situated thereinState.

Appears in 1 contract

Samples: Income and Capital Tax Convention

RESIDENT. 1. 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 the person’s domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and . This term also includes that State and any political subdivision or local authority thereof, or any agency or instrumentality of that State, subdivision or local authority. 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 capital situated thereinState.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. 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 capital situated therein.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of incorporation, place of management 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 or capital gains from sources in that State or capital situated thereinState.

Appears in 1 contract

Samples: Tax Agreement

RESIDENT. 1. 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 taxation therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. 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 capital situated therein.

Appears in 1 contract

Samples: Income and Capital Tax Convention

RESIDENT. 1. 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, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision administrative-territorial subdivisions or local authority thereofauthority. 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 capital property situated therein.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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 taxation therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This termterm does not, however, does not include any person persons who is are liable to tax taxation in that State in respect only of on income from sources or capital located in that State or capital situated thereinState.

Appears in 1 contract

Samples: Income and Capital Tax Convention

RESIDENT. 1. For the purposes purpose 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, place of management or any other criterion of a similar nature; it also means, and also includes that State and any political subdivision or local authority thereofin the case of Belgium, companies (other than companies with share capital) which have elected to have their profits subjected to the individual income tax. This term, however, However this term does not include any person who is liable to tax in that a Contracting State in respect only of income from sources in that State or capital situated therein.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of incorporation, place of management or any other criterion of a similar nature, 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 capital situated therein.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. For the purposes of this ConventionAgreement, 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, place of management management, place of registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. 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 capital (property) situated therein.

Appears in 1 contract

Samples: Income and Capital Tax Agreement

RESIDENT. 1. 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, place of management or any other criterion of a similar nature, and also includes that State State, and any political or administrative territorial subdivision or local authority thereof. This term, however, 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 capital situated therein.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management management, place of incorporation or any other criterion of a similar nature, 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 capital situated therein.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State” means " means: (a) any person who, under the laws of that State, is liable to tax therein by reason of his the person's domicile, residence, place of management management, place of registration, place of 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, but does not include any person who is liable to tax in that State in respect only of income from sources in that State, and (b) that State or capital situated thereina political subdivision or local authority thereof or any agency or instrumentality of any such State, subdivision or authority.

Appears in 1 contract

Samples: Income Tax Convention

RESIDENT. 1. For the The purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that StateState , is liable to tax therein by reason of his domiciledomicile , residenceresidence , place of management , place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereofauthority. 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 located in that State or capital situated therein.

Appears in 1 contract

Samples: Double Taxation Agreement

RESIDENT. 1. 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, place of incorporation, residence, place of management or any other criterion of a similar nature, and . The term also includes the Government of that Contracting State and any political subdivision or a local authority thereof. This term, however, But 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 capital situated therein.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management management, 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 capital situated thereinState.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. 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 capital situated therein.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. For the The purposes of this Convention, the term "resident of a Contracting State" means any person whowho , under the laws law of that StateState , is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature. However, and also includes that State and any political subdivision or local authority thereof. This term, 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 capital situated thereinState.

Appears in 1 contract

Samples: Double Taxation Agreement

RESIDENT. 1. 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, place of management or any other criterion of a similar nature, and also includes that State and State, any political subdivision or local authority thereof. This term, 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 capital situated thereinState.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management management, place of registration 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 capital situated thereinState.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, legal head office (place of management incorporation), place of man- agement 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 capital situated thereinState.

Appears in 1 contract

Samples: Convention for the Elimination of Double Taxation

RESIDENT. 1. 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, ,place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. 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 capital situated thereinState.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of incorporation, place of management 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 capital situated thereinState.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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 income tax therein by reason of his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political or administrative 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 capital situated therein.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. - 1. ) 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, place of management management, place of 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, But this term does not include any person who is liable to tax in that State in respect only of income from sources situated in that State or capital situated thereinState.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws law of that State, is liable to tax taxation therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, term does not include any person individuals who reside in the State and is liable only subject to tax taxes on income received from natural sources located in that State in respect only of income from sources in that State or capital situated thereinthe State.

Appears in 1 contract

Samples: Income Tax Convention

RESIDENT. 1. For the purposes of this ConventionAgreement, 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 that person's domicile, place of registration, residence, place of management 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 capital (property) situated therein.

Appears in 1 contract

Samples: Income and Capital Tax Agreement

RESIDENT. 1. 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, place of effective management 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 capital situated therein.

Appears in 1 contract

Samples: Protocol Amending Double Taxation Convention

RESIDENT. 1. 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, place of management 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 capital situated therein.incorporation,

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This termHowever, however, does a person will not include any person who is be deemed to be a resident of a Contracting State by virtue only of his being liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

Appears in 1 contract

Samples: Income and Capital Tax Convention

RESIDENT. 1. 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, place of management management, or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. 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 capital situated therein.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of management 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 or capital gains from sources in that State State, or capital situated therein.

Appears in 1 contract

Samples: Income and Capital Tax Treaty

RESIDENT. 1. 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, place of management head or main office, place of management, or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. 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 capital situated thereinState.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

RESIDENT. 1. 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, place of incorporation of a legal person by registration, place of management 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 capital situated therein.

Appears in 1 contract

Samples: Income and Capital Tax Treaty

RESIDENT. 1. 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, place of registration, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, 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 thereinState.

Appears in 1 contract

Samples: Income Tax Treaty