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 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 or statutory body thereof.
Appears in 6 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation 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 his domicile, residence, place of management or head office, or any other criterion of a similar nature nature, and also includes that State and any political subdivision, 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.
Appears in 5 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Agreement
RESIDENT. 1. For the purposes of this 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 his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, local authority or statutory body thereof.
Appears in 5 contracts
Samples: Double Taxation Agreement, Avoidance of Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
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 his domicile, residence, place of head office, place of effective management or any other criterion of a similar nature and also includes that State and any political subdivision, local authority or statutory body thereofnature.
Appears in 5 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 his that person’s domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, subdivision or local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources therein.
Appears in 5 contracts
Samples: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement for the Avoidance of Double Taxation, Double Taxation 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 his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, subdivision or local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 5 contracts
Samples: Income Tax Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 his their domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, subdivision or local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 5 contracts
Samples: Double Tax Agreement, Agreement for the Elimination of Double Taxation, Agreement for the Elimination of Double Taxation
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 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 or statutory body thereofnature.
Appears in 4 contracts
Samples: Convention for the Avoidance of Double Taxation, Double Taxation Agreement, Convention for the Avoidance of Double Taxation
RESIDENT. 1. For the purposes of this 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 his domicile, residence, place of management head office (place of effective management) or any other criterion of a similar nature and also includes that State and any political subdivision, local authority or statutory body thereofnature.
Appears in 4 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Agreement, Double Taxation 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 his that person's domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, subdivision or local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources therein.
Appears in 4 contracts
Samples: Income Tax Agreement, Income Tax Agreement, Income Tax 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 his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, subdivision or local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources situated in that State.
Appears in 4 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 his domicile, residence, place of management registration, place of incorporation, place of management, or any other criterion of a similar nature nature, and also includes that State and or any political subdivision, local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 4 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
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 his that person’s domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, local authority or statutory body thereof.
Appears in 4 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 his domicile, residence, place of management management, place of registration 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 in respect only of income from sources in that State or statutory body thereofcapital situated therein.
Appears in 4 contracts
Samples: Agreement for the Avoidance of Double Taxation, Income Tax Agreement, Income and Capital Tax 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 his domicile, residence, place of incorporation, place of effective management, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 4 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 his that person’s domicile, residence, place of registration, place of management or any other criterion of a similar nature nature, and also includes that Contracting State and any political subdivision, local authority or statutory body thereof.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 resident of 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 or statutory body thereoffor the purposes of the taxes of that State to which the Agreement applies.
Appears in 3 contracts
Samples: Double Taxation Agreement, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
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 his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature and nature. The term also includes the Government of that State itself, its political subdivisions and local authorities. This term does not include any political subdivision, local authority 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.
Appears in 3 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation 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 his domicile, residence, place of management or any other criterion of a similar nature and also includes that State and any political subdivision, subdivision or local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Double Tax Treaty
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 his that person’s domicile, residence, place of incorporation, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, subdivision or local authority or statutory body thereof.thereof as well as a recognised pension fund of that State. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 3 contracts
Samples: African Model Agreement for the Elimination of Double Taxation With Respect to Taxes on Income and the Prevention of Tax Avoidance and Evasion, African Model Agreement for the Elimination of Double Taxation, African Model Agreement for the Elimination of Double Taxation With Respect to Taxes on Income and the Prevention of Tax Avoidance and Evasion
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 his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature nature, and also includes that State and any political subdivision, local authority or statutory body thereof.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and State, any political subdivision, local authority or a statutory body thereof.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, Income Tax Agreement, Double Taxation Avoidance 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 his domicile, residence, place of management or any other criterion of a similar nature and also includes that nature. A Contracting State itself, and any political subdivision, subdivision or local authority or statutory body thereofthereof shall be deemed to be a resident of that State.
Appears in 3 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance 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, who is liable to tax therein as a resident for tax purposes of that Contracting State by reason of his domicile, residence, place of head office, place of control and management or any other criterion of a similar nature and also includes in accordance with the tax law of that State and any political subdivision, local authority or statutory body thereofContracting State.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 his that person’s domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that Contracting State and any political subdivision, subdivision or local authority or statutory body 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 Contracting State.
Appears in 3 contracts
Samples: Agreement for the Elimination of Double Taxation, Double Tax Agreement, Agreement for the Elimination of Double Taxation
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 his domicile, residence, place of incorporation or registration, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, local authority or statutory body thereof.
Appears in 3 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
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 his domicile, residence, place of management management, place of incorporation, place of registration 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.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
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 his domicile, residence, place of registration, place of incorporation, place of management or any other criterion of a similar nature and also includes nature. This term, 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.
Appears in 3 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance 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 his domicile, residence, place of management incorporation, place of head office or any other criterion of a similar nature and also includes that State and any political subdivision, local authority or statutory body thereofnature.
Appears in 3 contracts
Samples: Double Taxation Agreement, Income and Property Tax Agreement, Agreement for the Avoidance of Double Taxation
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 his domicile, residence, place of management registration, place of management, or any other criterion of a similar nature and also includes that State and any political subdivision, or administrative subdivision or local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 his domicile, residence, place of management 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 in respect only of income from sources in that State or statutory body thereofcapital situated therein.
Appears in 3 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance 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 his domicile, residence, place of management management, place of head or main office or any other criterion of a similar nature nature, and also includes that State Contracting State, any federal state (Land) thereof and any political subdivision, subdivision or local authority or statutory body 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 Contracting State.
Appears in 3 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 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 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 or statutory body thereofnature.
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 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 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, subdivision or local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 2 contracts
Samples: Income Tax Agreement, Income and Capital Gains Tax 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 his domicile, residence, place of incorporation, place of management 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.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance 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 his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivisionState, a local authority or statutory body thereof.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, local authority or statutory body thereof.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. 1. For the purposes purpose 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 his domicile, residence, place of management or any other criterion of a similar nature and also includes nature. The 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.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance 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 his domicile, residence, place of head office, place of registration, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, or local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 2 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
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 his domicile, residence, place of management or any other criterion of a similar nature 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 statutory body thereofcapital situated therein.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation 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 his that person’s domicile, residence, legal head office (registered office), place of management or any other criterion of a similar nature and also includes that State and any political subdivision, subdivision or local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources therein.
Appears in 2 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 his domicile, residence, place of incorporation, place of management or any other criterion criteria of a similar nature nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 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.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
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 his domicile, residence, place of management management, place of registration, place of incorporation or any other criterion of a similar nature nature, and also includes that State and any political subdivision, 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 or statutory body thereofcapital gains from sources in that State or capital situated therein.
Appears in 2 contracts
Samples: Tax Agreement, Double Taxation 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 that. State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature and also includes nature. This term 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 thereofproperty situated therein.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State State, a “Land” and any political subdivision, subdivision or local authority of that State or statutory body thereof“Land”. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 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 or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Income Tax 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, State is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature and also includes nature. This term, 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.
Appears in 2 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 his that person’s domicile, residence, place of management or any other criterion of a similar nature and also nature, and, where applicable, includes that State and any political subdivision, subdivision or local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance 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 his domicile, residence, place of management incorporation, place of head or main office or any other criterion of a similar nature nature, and also includes that Contracting State and any political subdivision, subdivision or local authority or statutory body 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 Contracting State.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 his domicile, residence, place of incorporation (or registration), place of management or any other criterion of a similar nature and nature. The term also includes that State and any political subdivision, local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a .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 effective management, head office or any other criterion of a similar nature and also includes that State and any political subdivision, local authority or statutory body thereofnature.
Appears in 2 contracts
Samples: Double Taxation Agreement, Double Taxation 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 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 or statutory body thereof.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 his domicile, residence, duration of his stay, place of management 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 in respect only of income from sources in that State or statutory body thereofcapital situated therein.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation 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 his domicile, residence, place of management management, place of registration or any other criterion of a similar nature nature, and also includes that State and any political subdivision, subdivision or local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 his domicile, residence, place of management management, place of registration or any other criterion of a similar nature and also includes that State and any political subdivision, local authority or statutory body thereofnature.
Appears in 2 contracts
Samples: Income Tax Agreement, Agreement for the Avoidance of Double Taxation
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 his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature nature, and also includes that State State, a Land and any political subdivision, subdivision or local authority or statutory body thereof.
Appears in 2 contracts
Samples: Double Taxation Agreement, Double Taxation Avoidance 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 his domicile, residence, place of management 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 in respect only of income from sources in that State or statutory body thereofcapital situated therein.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Income and Capital Tax Agreement
RESIDENT. 1. For the purposes of this 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 his domicile, residence, place of management management, place of registration 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 in respect only of income from sources in that State or statutory body thereofcapital situated therein.
Appears in 2 contracts
Samples: Double Taxation Agreement, Income and Capital Tax Treaty
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 his domicile, residence, place of management 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 situated in that State.
Appears in 2 contracts
Samples: Double Taxation Agreement, Double Taxation 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 his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivisionState, local authority or statutory body thereof.
Appears in 2 contracts
Samples: Double Taxation Agreement, Double Taxation 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 his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 his domicile, residence, place of management 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.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Income Tax Agreement
RESIDENT. 1. For the purposes purpose 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 his domicile, residence, place of registration, place of management or any other criterion of a similar nature and also includes that State and any political subdivision, local authority or statutory body thereofnature.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Income Tax 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 his domicile, residence, place of management registration, place of management, or any other criterion of a similar nature and nature. The term “resident of a Contracting State” also includes that State or its local authorities or a legal person organized under the laws of a Contracting State and that is generally exempt from tax in that State. This term, however, does not include any political subdivision, local authority or statutory body thereofperson who is liable to tax in that State in respect only of income from sources in that State.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 taxation therein by reason of his domicile, residence, place of management management, place of incorporation, or any other criterion of a similar nature and also includes that State and any political subdivision, local authority or statutory body thereofnature.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation
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 his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, local authority or statutory body thereof.
Appears in 2 contracts
Samples: Double Taxation Agreement, Agreement for the Elimination of Double Taxation
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 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 or statutory body thereof.his
Appears in 1 contract
Samples: Employment Contract
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 his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature nature, and also includes that State and State, any political subdivision, local authority or statutory body thereof.political
Appears in 1 contract
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 his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature nature, and also includes that State and any political subdivision, 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.
Appears in 1 contract
Samples: Double Taxation 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 his domicile, residence, registered office, place of management effective management, or any other criterion of a similar nature nature, and also includes that State and any political subdivision, subdivision or local authority or statutory body thereof. 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.
Appears in 1 contract
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 taxation therein by reason of his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature and also includes that State and any political subdivision, local authority or statutory body thereofnature.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
RESIDENT. 1. For the purposes purpose 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 his nationality, domicile, residence, place of head office or registration, 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 thereofnature.
Appears in 1 contract
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 his that person's domicile, residence, place of management or any other criterion of a similar nature and also includes that State and any political subdivision, local authority or statutory body thereof.of
Appears in 1 contract
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 his that person’s domicile, place of registration, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, 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 (property) situated therein.
Appears in 1 contract
Samples: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion
RESIDENT. 1. For the purposes of this Agreement, the term “« resident of a Contracting State” 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 mana- gement or any other criterion of a similar nature and also includes that State and any political subdivision, subdivision or local authority or statutory body thereofthe- reof. 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.
Appears in 1 contract
Samples: Tax Treaty
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 his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, 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.
Appears in 1 contract
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 his domicile, residence, legal head office, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, subdivision or local authority or statutory body thereof, This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
Samples: Income Tax 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 his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature nature, and also includes that State and any political subdivision, local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
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 his domicile, residence, legal head office, place of management or any other criterion of a similar nature nature, and also includes that State State, a Land and any political subdivision, subdivision or local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
Samples: Double Taxation Agreement
RESIDENT. 1. For the purposes of this Agreement, 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 residence, domicile, residenceplace of registration, place of management or any other criterion of a similar nature nature, and also includes that State and State, any political subdivision, subdivision or any local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
Samples: Agreement for the Avoidance of Double Taxation and Fiscal Evasion With Respect to Taxes on Income
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 his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, 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.
Appears in 1 contract
Samples: Income and Capital Tax 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 his domicile, residence, place of management registration, residence 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 thereofproperty situated therein.
Appears in 1 contract
Samples: Income and Property Tax Agreement
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a the Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management management, registered office or any other criterion of a similar nature and also includes nature. However, the 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.
Appears in 1 contract
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 his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, political- administrative subdivision or local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
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 his domicile, residence, place of management head or main office, place of registration, place of management, or any other criterion of a similar nature nature, and also includes that State and any political subdivision, subdivision or local authority or statutory body thereof.
Appears in 1 contract
Samples: Income Tax 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 his domicile, residence, place of management or any other criterion of a similar nature and also includes nature. This term, 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.
Appears in 1 contract
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 his domicile, residence, place of management registration 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 in respect only of income from sources in that State or statutory body thereofcapital situated therein.
Appears in 1 contract
RESIDENT. 1. For the purposes purpose of this Agreement, the term “resident of resident, in relation to a Contracting State” , means any a person who, under the laws of that State, who is fully liable to tax therein by reason of his domicile, residence, place being a resident of management or any other criterion of a similar nature and also includes that State and any political subdivision, local authority or statutory body thereofunder the tax law of that State.
Appears in 1 contract
Samples: International Tax Agreements
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 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 or statutory body thereof.or
Appears in 1 contract
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 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 thereofnature.
Appears in 1 contract
Samples: Double Taxation Avoidance 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 his residence, domicile, residence, place of management effective management, or any other criterion of a similar nature nature, and also includes that State and any political subdivision, 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.
Appears in 1 contract
Samples: Income and Capital Tax Agreement
RESIDENT. 1. For the purposes purpose 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 his domicile, residence, place of incorporation or registration, place of management or any other criterion of a similar nature and also includes nature, but 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.
Appears in 1 contract
Samples: Double Taxation 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 his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivisionState, local authority or statutory body thereof.
Appears in 1 contract
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 his domicile, residence, place of management registration, place of management, or any other criterion of a similar nature and nature. The term "resident of a Contracting State" also includes that State or its local authorities or a legal person organized under the laws of a Contracting State and that is generally exempt from tax in that State. This term, however, does not include any political subdivision, local authority or statutory body thereofperson who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means means; any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature and also includes that State and any political subdivision, subdivisions 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.
Appears in 1 contract
Samples: Double Taxation 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, individual who is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature and also includes ordinarily resident in that State and any political subdivision, local authority or statutory body thereoflegal person which has its place of management in that State.
Appears in 1 contract
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 his domicile, residence, place of head office, place of control and management or any other criterion of a similar nature and also includes that State and any political subdivision, local authority or statutory body thereofnature.
Appears in 1 contract
Samples: Income Tax 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 his domicile, residence, place of management management, place of registration or any other criterion of a similar nature and also includes that State and any political subdivision, local authority or statutory body thereofnature.
Appears in 1 contract
RESIDENT. 1. For the purposes purpose of this Agreement, the term “resident of resident, in relation to a Contracting State” , means any a person who, under the laws of that State, who is fully liable to tax therein by reason of his domicile, residence, place being a resident of management or any other criterion that State under the tax law of that State.
2. A person is not a resident of a similar nature and also includes Contracting State for the purposes of this Agreement if the person 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.
Appears in 1 contract
Samples: International Tax Agreements
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 his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision, local authority or statutory body thereof.
Appears in 1 contract
Samples: Double Taxation Agreement