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, 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 16 contracts
Samples: Convention for the Avoidance of Double Taxation, Income and Capital Tax Treaty, 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, place of incorporation 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 12 contracts
Samples: Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement, Double Taxation Avoidance 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, place of incorporation 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 12 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 Contracting State, is liable to tax therein by reason of his domicile, residence, place of managementhead or main office, place of incorporation management or any other criterion of a similar nature, 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 12 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 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, 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 11 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 Contracting State, is liable to tax therein by reason of his domicile, residence, place of managementhead or main office, place of incorporation management or any other criterion of a similar nature, 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 10 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 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, 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 Contracting State, is liable to tax therein by reason of his domicile, residence, place of managementhead or main office, place of incorporation 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 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 10 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 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, place of incorporation management 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 thereinState.
Appears in 8 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, 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 7 contracts
Samples: Double Taxation Agreement, 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 managementincorporation, place of incorporation 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 thereinState.
Appears in 7 contracts
Samples: Agreement for the Elimination of Double Taxation, Agreement for the Elimination of Double Taxation, Agreement 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, place of incorporation 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 6 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, place of incorporation 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 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 domicile, residence, place of managementincorporation, place of incorporation management or any other criterion xxxxx- xxxx 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 thereinState.
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 domicile, residence, place of management, place of incorporation 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.
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 management, place of incorporation management or any other criterion of a similar nature, and also includes that State and any political subdivision territorial authority or local authority 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 5 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, place of incorporation or any other criterion of a similar nature, and . The term also includes that State itself, its political subdivisions and any political subdivision or local authority thereofauthorities. 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, 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 management, place of incorporation head or main office 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 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 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, place of incorporation 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, 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 managementhead or main office, place of incorporation 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 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 5 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 managementincorporation, place of incorporation 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 5 contracts
Samples: Double Taxation Agreement, 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 Contracting State, is liable to tax therein by reason of his domicile, residence, place of head or main office, place of management, place of incorporation 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 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 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, place of incorporation 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 5 contracts
Samples: Convention for the Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion, 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, 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 4 contracts
Samples: Income 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 managementregistration, place of incorporation management or any other criterion of a similar nature, and also includes that State and any political 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 property 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 managementincorporation (registration), place of incorporation 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 4 contracts
Samples: Income Tax Treaty, 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, 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 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, place of incorporation 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, place of incorporation management or any other criterion of a similar nature, and also includes that State and any political or administrative subdivision or local authority au- thority 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 of that State, is liable to tax therein by reason of his domicile, residence, place of managementincorporation, place of incorporation management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, howeverhow- ever, 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: Double Taxation Convention, Double Taxation Convention, Double Taxation Convention
RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any Any person who, under the laws of that State, is liable to tax therein taxes in that state by reason of his domicile, residence, place of management, place of incorporation 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 State. The government of any of the two contracting states or capital situated thereinany of its political subdivision or local authorities.
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 management, place of incorporation 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: 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, place of incorporation management or any other criterion of a similar nature, and also includes that State and any political or administrative subdivision or local authority au- thority 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 Contracting State, is liable to tax therein by reason of his domicile, residence, place of managementincorporation, place of incorporation 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 3 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 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 management, place of incorporation head or main office 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 3 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 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, place of incorporation 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 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 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 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 of that State, is liable to tax therein by reason of his domicile, residence, place of management, place of incorporation 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 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 Contracting State, is liable to tax therein by reason of his domicile, residence, place of managementhead or main office, place of incorporation management or any other criterion of a similar nature, 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.includes:
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 Contracting State, is liable to tax therein by reason of his domicile, residence, place of head or main office, place of management, place of incorporation or any other criterion of a similar nature, and also includes that Contracting State and any political subdivision or local authority thereof, as well as a 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 3 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 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, place of incorporation 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 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 Contracting State, is liable to tax therein by reason of his domicile, residence, place of managementhead or main office, place of incorporation 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 3 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 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, place of incorporation 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 3 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 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 managementincorporation, place of incorporation management 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 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, Convention the term "“resident of a Contracting State" ” means any person who, who under the laws of that State, State is liable to tax therein by reason of his domicile, domicile residence, place of managementincorporation, place of incorporation management or any other criterion of a similar nature, and also includes that State and any political subdivision 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 Avoidance Agreement, 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 management, place of incorporation head or main office or any other criterion of a similar nature, and also includes that Contracting State and any political or administrative subdivision or local authority thereof. This term, howeverhowev- er, 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 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 managementincorporation or place of registration, place of incorporation 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 domicile, residence, place of managementincorporation, place of incorporation management or any other criterion of a similar nature, and also includes that State and any political subdivision 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 Avoidance Agreement, 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, place of incorporation incorporation, or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinof profits attributable to a permanent establishment in that State. .
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 StateState " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management, place of incorporation 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, place of incorporation management or any other criterion of a similar nature, nature and also includes that State and any political or administrative subdivision or local authority au- thority 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, place of incorporation 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 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 managementincorporation, place of incorporation 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, State is liable to tax therein by reason of his domicile, residence, place of management, place of incorporation 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 But this term shall 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 Contracting State, is liable to tax therein by reason of his domicile, residence, place of management, place of incorporation head or main office or any other criterion of a similar nature, and also includes that Contracting 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 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 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, place of incorporation or any other criterion xxxxx- xxxx 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 situated 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, place of incorporation 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 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, place of incorporation 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 therein. For the purposes of this Convention, the Government of a Contracting State, its political subdivisions and local authorities thereof will be considered to be a resident of that Contracting State.
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 managementregistration, place of incorporation incorporation, place of management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit, 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: 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 taxation therein by reason of his domicile, residence, place of management, place of incorporation 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 State, or capital situated therein.
Appears in 2 contracts
Samples: Agreement for Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
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, place of incorporation 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 state in respect only of income from sources in that State or capital situated thereinstate.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, 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, 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 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 State, is liable to tax therein by reason of his domicile, residence, place of managementregistration, place of incorporation management or any other criterion of a similar nature, and also includes that State and any political or 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 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 management, place of incorporation incorporation, place of head or main office 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 managementincorporation, place of incorporation 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, 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, place of incorporation 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 2 contracts
Samples: 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 Contracting State, is liable to tax therein by reason of his domicile, residence, place of managementhead or main office, place of incorporation management or any other criterion of a similar nature, 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 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 managementincorporation, place of incorporation management or any other criterion of a similar nature, and also includes that State and any political subdivision subdi- vision or local authority thereof. This term, however, does not include in- clude 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: Model Double Taxation Convention, Model 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 managementregistration, place of incorporation management 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 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, place of incorporation or any other criterion of a similar nature, and . The term also includes the Government of that State itself, its political subdivisions and local authorities and any agency or wholly-owned entity of such State, political subdivision or local authority thereofthat is established under the laws of that State. 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
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, place of incorporation management or any other criterion of a similar nature, and also includes that State 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
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 managementnationality, place of incorporation 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 property situated therein.
Appears in 1 contract
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, place of incorporation or any other criterion of a similar nature, and also includes that State and any political 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 1 contract
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, place of incorporation or any other criterion of a similar nature, and also includes that State State, and any political subdivision or local authority thereofthereof and any pension fund or pension scheme recognised by 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 1 contract
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, 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 1 contract
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, place of incorporation 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
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 managementincorporation, place of incorporation management or any other criterion of a similar nature, ; and this term shall also includes that include the State itself and any political subdivision or its 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 situated thereinState.
Appears in 1 contract
Samples: 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, place of incorporation or any other criterion of a similar nature; and this term shall also include the State itself, its local authorities and also includes that State and any political subdivision or local authority thereofstatutory bodies. 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: 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 managementregistration or incorporation, place of incorporation 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
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 managementincorporation (registration), place of incorporation 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: 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 managementincorporation, place of incorporation 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
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, place management 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 1 contract
Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
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, 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 1 contract
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 managementhead or main office, place of incorporation 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 1 contract
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, place of incorporation incorporation, 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.includes:
Appears in 1 contract
Samples: 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, place of incorporation 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 thereinin the Contracting State.
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, place of incorporation 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 property situated therein.
Appears in 1 contract
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, place of incorporation incorporation, or any other criterion of a similar nature, and also includes that Contracting State and any political subdivision or local and governmental 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 thereinof profits attributable to a permanent establishment in that State.
Appears in 1 contract
RESIDENT. 1. For the purposes of this Convention, the term "" resident of a Contracting StateState " 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, place of incorporation 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: 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 head or main office, place of management, place of incorporation 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 1 contract
RESIDENT. 1. For the purposes of this Convention, the term "“resident of a Contracting State" Country” means any person who, under the laws of that StateCountry, is liable to tax therein by reason of his domicile, residence, registration, place of management, place of incorporation or any other criterion of a similar nature, and also includes that State Country and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State Country in respect only of income from sources in that State Country or capital situated therein.
Appears in 1 contract
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, 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 1 contract
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, 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 But 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
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 managementhead or main office, place of incorporation 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, 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
RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any means
a. Any person who, under the laws of that State, is liable to tax therein taxes in that state by reason of his domicile, residence, place of management, place of incorporation 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 State.
b. The government of any of the two contracting states or capital situated thereinany of its political subdivision or local authorities.
Appears in 1 contract
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 managementincorporation, place of incorporation 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: 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, place of incorporation or any other criterion of a similar nature, nature and also includes that State and any political subdivision regional or local authority thereof. It shall include also any pension or other employee benefit plan, and any charitable organisation, established under the law of a Contracting State. 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
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 managementincorporation, place of incorporation 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
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, 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 therein.
Appears in 1 contract
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, place of incorporation registration or any other criterion of a similar nature, and also includes that State and any political administrative - territorial unit/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