Common use of RESIDENT Clause in Contracts

RESIDENT. 1. For the purposes of this Agreement, 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 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, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s status shall be determined as follows: (a) the individual shall be deemed to be a resident only of the State in which a permanent home is available to the individual; if a permanent home is available to the individual in both States, the individual shall be deemed to be a resident only of the State with which the individual's personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s centre of vital interests cannot be determined, or if a permanent home is not available to the individual in either State, the individual shall be deemed to be a resident only of the State in which the individual has an habitual abode; (c) if the individual has an habitual abode in both States or in neither of them, the individual shall be deemed to be a resident only of the State of which the individual is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, 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 that person’s his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority (in the case of Romania, administrative - territorial unit) or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both Contracting States or in neither of them, the individual he shall be deemed to be a resident only of the Contracting State of which the individual he is a national; (d) in any other caseif 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.

RESIDENT. 1. For the purposes of this AgreementConvention, 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 that person’s his domicile, residence, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority in respect only of income from sources in that State or statutory body thereofcapital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, 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 that person’s 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, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the Contracting State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both Contracting States, the individual he shall be deemed to be a resident only of the Contracting State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the Contracting State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either Contracting State, the individual he shall be deemed to be a resident only of the Contracting State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both Contracting States or in neither of them, the individual he shall be deemed to be a resident only of the Contracting State of which the individual he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, 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 that person’s 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 county government, political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. 1. For the purposes of this Agreement, 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 that person’s his domicile, residence, place of management or any other criterion of a similar nature. This term, and also includes however, does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. 2. Where by reason of the provisions of paragraph 1 1, an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if a he has no permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax Lax therein by reason of that person’s his domicile, residence, place of incorporation, place of management or any other criterion of or a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the Contracting State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, 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 that person’s his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available avai­lable to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting Con­tracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, 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 that person’s his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as followsfollows : (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim ; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means means: (i) any person who, under the laws of that State, is liable to tax therein by reason of that person’s his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, ; (ii) and also includes that State and State, any political subdivision, local authority or a statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, 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 that person’s his domicile, residence, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority in respect only of income from sources in that State or statutory body thereofcapital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, 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 that person’s his domicile, residence, place of registration, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority in respect only of income from sources in that State or statutory body thereofcapital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a nationalcitizen; (d) in any other caseif both States consider him to be their citizen or if he is a citizen of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, 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 that person’s his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and Contracting State, any political subdivision, local authority or a statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the Contracting State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both Contracting States, the individual he shall be deemed to be a resident only of the Contracting State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the Contracting State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either Contracting State, the individual he shall be deemed to be a resident only of the Contracting State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both Contracting States or in neither of them, the individual he shall be deemed to be a resident only of the Contracting State of which the individual he is a national; (d) in any other caseif 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.

RESIDENT. 1. For the purposes of this Agreement, 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 that person’s his domicile, residence, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority in respect only of income from sources in that State or statutory body thereofcapital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual shall be deemed to be a resident only of the State of which the individual is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement. Where by reason of the provisions of paragraph 1 a company is a resident of both Contracting States, then it shall be deemed to be a resident of the State in which its place of effective management is situated.

RESIDENT. 1. For the purposes of this AgreementConvention, 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 that person’s his domicile, residence, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the Contracting State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both Contracting States, the individual he shall be deemed to be a resident only of the Contracting State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the Contracting State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either Contracting State, the individual he shall be deemed to be a resident only of the Contracting State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both Contracting States or in neither of them, the individual he shall be deemed to be a resident only of the Contracting State of which the individual he is a national; (d) in any other caseif 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.

RESIDENT. 1. For the purposes of this AgreementConvention, 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 that person’s his domicile, residence, place of management or any other criterion of a similar nature. This term, and also includes however, does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, 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 that person’s his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual shall be deemed to be a resident only of the State of which the individual is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, 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 that person’s his domicile, residence, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority in respect only of income from sources in that State or statutory body thereofcapital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: : (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); ; (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; ; (c) if the individual he has an habitual abode in both States or in neither of them, the individual shall be deemed to be a resident only of the State of which the individual is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, 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 that person’s 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, 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 statutory body thereofcapital situated therein. 2. Where by reason of the provisions of paragraph 1 of this Article, an individual is a resident of both Contracting States, then the individual’s status shall be determined as follows:a (a) the individual he shall be deemed to be a resident only of the Contracting State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both Contracting States, the individual he shall be deemed to be a resident only of the Contracting State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s centre of vital interests cannot be ; determined, or if he has not a permanent home is not available to the individual him in either Contracting State, the individual he shall be deemed to be a resident only of the Contracting State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both Contracting States or in neither of them, the individual he shall be deemed to be a resident only of the Contracting State of which the individual he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, 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 that person’s his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the Contracting State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both Contracting States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the Contracting State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either Contracting State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both Contracting States or in neither of them, the individual he shall be deemed to be a resident only of the Contracting State of which the individual he is a national; (d) in any other caseif 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.

RESIDENT. 1. For the purposes of this AgreementConvention, 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 that person’s his domicile, residence, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that in that State and any political subdivision, local authority in respect only of income from sources in that State or statutory body thereofcapital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, 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 that person’s his domicile, residence, place of management management, or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority in respect only of income from sources in that State or statutory body thereofcapital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he does not have a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement 3. Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the State in which its place of effective management is situated.

RESIDENT. 1. For the purposes of this Agreement, Agreement the term "resident of a Contracting State" means any means: (a) in the case of Malaysia, a person whowho is resident in Malaysia for the purposes of Malaysian tax; and (b) in the case of the U.S.S.R., under a person who is resident in the laws U.S.S.R. for the purposes of that State, is liable to tax therein by reason of 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, local authority or statutory body thereofthe U.S.S.R. tax. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as followsin accordance with the following rules: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individual; if him. If he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a nationalcitizen; (d) in any other caseif either State regards him as its citizen or if he is a citizen of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, 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 that person’s his domicile, residence, place of management or any other criterion of a similar nature, and also includes . But this term does not include a person who is liable to tax in that State and any political subdivision, local authority in respect only of income from sources in that State or statutory body thereofon capital situated therein. 2. Where by reason of the provisions of paragraph 1 1, an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual a. he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) b. if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) c. if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national;; and (d) in any other cased. if he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, 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 that person’s his domicile, residence, place of management or any other criterion of a similar nature. This term, and also includes however, does not include any person who is liable to tax in that State and any political subdivision, local authority in respect only of income from sources in that State or statutory body thereofcapital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre center of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason reasons of that person’s his domicile, residence, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority in respect only of income from sources in that State or statutory body thereofcapital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre center of vital interests); (b) if the State in which the individual’s centre he has his center of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, 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 that person’s his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, 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 that person’s his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows:; (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interestsinterests ); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States State shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, the term "resident of a Contracting State" means any person whowhose income or capital, under the laws of that State, is liable to tax therein by reason of that person’s his domicile, residence, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority in respect only of income from sources in that State or statutory body thereofcapital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, 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 that person’s his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes .But this term does not include any person who is liable to tax in that State and any political subdivisionin respect only of income from sources in that State, local authority or statutory body thereofcapital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a1) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre ( center of vital interests); (b2) if the State in which the individual’s centre he has his center of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c3) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d4) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by a mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, 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 that person’s his domicile, residence, place of management incorporation, residence or any other criterion of a similar nature, and also includes nature but this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual inpidual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the Contracting State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both Contracting States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the Contracting State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both Contracting States or in neither of them, the individual he shall be deemed to be a resident only of the Contracting State of which the individual he is a national; (d) in any other caseif he is a national of neither of the Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, 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 that person’s his domicile, residence, place of registration, place of management or any other criterion of a similar nature. This term, and also includes however, does not include any person who is liable to tax in that State and any political subdivision, local authority in respect only of income from sources in that State or statutory body thereofcapital situated therein. 2. Where by reason of the provisions of paragraph 1 1, an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif each State considers him to be its national or if he is a national of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, 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 that person’s his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority in respect only of income from sources in that State or statutory body thereofcapital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, 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 that person’s his domicile, residence, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority in respect only of income from sources in that State or statutory body thereofcapital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are as closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, 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 that person’s his domicile, residence, place of registration, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority in respect only of income from sources in that State or statutory body thereofcapital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, 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 that person’s his domicile, residence, place of head or main office, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, 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 that person’s his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the State in which he has a permanent home is available to the individualhim; if a permanent he has apermanent home is available to the individual him in both States, the individual he shall be deemed to be a resident only of the State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both States or in neither of them, the individual he shall be deemed to be a resident only of the State of which the individual he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, 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 that person’s his domicile, residence, place of management head office, place of incorporation or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s his status shall be determined as follows: (a) the individual he shall be deemed to be a resident only of the Contracting State in which he has a permanent home is available to the individualhim; if he has a permanent home is available to the individual him in both Contracting States, the individual he shall be deemed to be a resident only of the Contracting State with which the individual's his personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s he has his centre of vital interests cannot be determined, or if he has not a permanent home is not available to the individual him in either Contracting State, the individual he shall be deemed to be a resident only of the State in which the individual he has an habitual abode; (c) if the individual he has an habitual abode in both Contracting States or in neither of them, the individual he shall be deemed to be a resident only of the Contracting State of which the individual he is a national; (d) in any other caseif 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.