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 their domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
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 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 their that person’s domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that Statetherein.
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 their his domicile, residence, place of management management, place of registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 5 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 their his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or subdivision, local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 5 contracts
Samples: Avoidance of 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 their that person’s domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or 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
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 their his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income or capital gains from sources in that State.
Appears in 4 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 their his domicile, residence, place of management management, place of registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital 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 their that person's domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that Statetherein.
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 their domicile, residence, place of management registration, place of incorporation, place of management, or any other criterion of a similar nature, and also includes that State and or 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.
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 their his domicile, residence, place of registration, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital 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 State, who is liable to tax therein as a resident for tax purposes of that Contracting State by reason of their his domicile, residence, place of head office, place of control and management or any other criterion of a similar nature, and also includes nature in accordance with the tax law of that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that Contracting 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 their his domicile, residence, place of management registration, place of management, or any other criterion of a similar nature, nature and also includes that State and any political or administrative subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
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 their his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, nature and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 3 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 their that person’s domicile, residence, place of registration, place of management or any other criterion of a similar nature, and also includes that Contracting 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 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 their his domicile, residence, place of management management, place of head or main office or any other criterion of a similar nature, and also includes that State Contracting State, any federal state (Land) thereof 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 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 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 their his domicile, residence, place of incorporation or registration, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or subdivision, local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
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 their his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or 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 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 their his domicile, residence, place of management or any other criterion of a similar nature. A Contracting State itself, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable or statutory body thereof shall be deemed to tax in that State in respect only be a resident of income from sources in 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, is liable to tax therein by reason of their his domicile, residence, place of management or any other criterion of a similar nature, nature and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
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 purpose of this Agreement, 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 their his domicile, residence, place of management or place of head office, 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.
Appears in 3 contracts
Samples: Income and Capital 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 their his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and State, any political subdivision or subdivision, local authority or a 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, 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 their his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State State, a Land and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Income and Capital Tax Agreement
RESIDENT. 1. For the purposes of this 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 their that person’s domicile, residence, place of management or any other criterion of a similar nature, and also and, where applicable, 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.
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 their his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State State, a “Land” and any political subdivision or local authority thereofof that State or “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 StateState 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 Contracting State, is liable to tax therein by reason of their his domicile, residence, place of management 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 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 their 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 State, 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 situated 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 their his domicile, residence, place of management management, place of registration, place of incorporation or any other criterion of a similar nature, and also includes that State and any political 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 capital gains from sources in that StateState 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 State, is liable to tax therein by reason of their his domicile, residence, place of management or any other criterion of a similar nature, nature and also includes that State and any political subdivision or 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 their his domicile, residence, place of management effective management, place of head office 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.
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 their 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 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.
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 their his domicile, residence, place of management registration, place of management, or any other criterion of a similar nature, and . 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 any political subdivision or local authority thereofthat is generally exempt from tax in 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 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 their his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, nature and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
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 their his domicile, residence, place of management management, place of registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
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 their his domicile, residence, place of incorporation, place of management or any other criterion criteria 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.
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 their his domicile, residence, duration of his stay, 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 StateState or capital 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 their his domicile, residence, place of management management, place of registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
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 of that State, is liable to tax therein by reason of their that person’s domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 2 contracts
Samples: 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 State, is liable to tax therein by reason of their 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 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 StateState or capital situated therein.
Appears in 2 contracts
Samples: Agreement for the Elimination 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 their his domicile, residence, place of management management, place of registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.
Appears in 2 contracts
Samples: Double Taxation Agreement, Income and Capital Tax Treaty
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 their his domicile, residence, place of management management, place of registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
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 their his domicile, residence, place of management or any other criterion of a similar nature, nature and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
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, is liable to tax therein by reason of their his domicile, residence, place of head office, place of registration, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, 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 their his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision administrative-territorial 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 StateState or capital 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 their that person’s domicile, residence, legal head office (registered office), place of management or any other criterion of a similar nature, nature and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that Statetherein.
Appears in 2 contracts
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 their his domicile, residence, place of management management, place of incorporation, or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
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 their his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or State, 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, 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 their his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
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 their his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.
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 their his domicile, residence, place of registration, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, 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, 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 their his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and also includes that State State, a Land and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
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 their his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or State, a 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 their his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or 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 AgreementConvention, the term “"resident of a Contracting State” " means any person whowhose income or capital, under the laws of that State, is liable subject to tax therein by reason of their his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
Samples: 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 their that person’s domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that Statetherein.
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 their his domicile, residence, place of management management, place of registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
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 their his domicile, residence, place of management management, registered office 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, the term does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital 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 their his domicile, residence, place of management or any other criterion of a similar nature, nature and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
Samples: Double Taxation Agreement
RESIDENT. 1. For the purposes of this Agreementagreement, 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 their his domicile, residence, place of management head office 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.
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 their his domicile, residence, place of management management, place of registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital (property) 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 contracting State, is liable to tax therein by reason of their his domicile, residence, place of head office or place of effective management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
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 Statestate, is liable to tax therein by reason of their 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 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.
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 their his domicile, residence, place of management incorporation, place of registration, place of management, principal place of business or any other criterion of a similar nature, and also includes that State and or any political subdivision or local authority authorities thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
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 their his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.registration as a
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 their his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
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 their 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 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.
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 their his domicile, residence, place of management (registered office) 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...
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 their his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.political
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 their his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, 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 StateState or capital 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 their 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 or local authority thereof. This term, however, does not include any legal person who is liable to tax in that State in respect only which has its place of income from sources 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 their 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 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.
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 their his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
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 their 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 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 StateState or property situated therein.
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 their his domicile, residence, place of management or any other criterion of a similar nature, and . The term “resident of a Contracting State” 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 means associations as well as partnerships deriving their status under the laws of income from sources in that a Contracting State.
Appears in 1 contract
Samples: Income Tax Convention
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 their his domicile, residence, place of management registration as legal entity 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.
Appears in 1 contract
Samples: 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 their his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or subdivision, local authority (in the case of Romania, administrative — territorial unit) 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 and Capital 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 who is a resident in a Contracting State for tax purposes of that State, is liable to tax therein by reason of their domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that Contracting State.
Appears in 1 contract
Samples: Income Tax Agreement
RESIDENT. 1. For the purposes of this Agreement, the term “"resident" means any person who is a resident of a Contracting State” means any person who, under State for the laws purposes of that State, is liable to tax therein by reason of their domicile, residence, place of management or any other criterion of a similar nature, and 's tax. The term also includes that a Contracting State and any political subdivision or local authority thereofof that State. This The 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 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 their his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
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 their his domicile, residence, place of management management, place of head office, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or State, a 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 their his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and State, any political subdivision or subdivision, local authority or a 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 StateState or capital 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 Contracting State, is liable to tax therein by reason of their his domicile, residence, place of management 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 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 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 their his 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 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 StateState or capital 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 their his domicile, residence, place of management management, place of registration, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, 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 the Prevention of Fiscal 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 their his domicile, residence, place of incorporation (or registration), place of management or any other criterion of a similar nature, and . The term 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.
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 their his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any administrative or political subdivision or local authority thereof. This term, however, term does not include any person who is liable to tax in that State in respect only of income from sources in that StateState 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 their his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, term does not include any person 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 their his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political administrative-territorial subdivision or local authority thereof. This term, however, 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 StateState or property 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 their that person’s domicile, residence, place of management incorporation, place of head or main office, place of management, principal place of business 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.
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 their his domicile, residence, place of head office, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.
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 Contracting State, is liable to tax therein by reason of their that person's domicile, residence, place of registration, place of management or any other criterion of a similar nature, and also includes that Contracting 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 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 their his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, nature and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
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 their domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
Samples: 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 their his domicile, residence, place of incorporation or 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 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, under the laws of that State, is liable to tax therein by reason of their his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital 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 their his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income or capital gains from sources in that StateState or capital situated therein.
Appears in 1 contract
Samples: Double Taxation 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 their his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.The term also includes:
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 their his domicile, residence, place of management or any other criterion of a similar naturemanagement, 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.place 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 their his domicile, residence, place of management or 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.
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 their his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, term however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or property situated therein.
Appears in 1 contract
RESIDENT. 1. For the purposes purpose of this Agreement, the term “resident of a Contracting State” means any a person who, under the laws of that State, is liable to tax therein by reason of their his domicile, residence, place of registration, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, 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 StateState or capital situated therein.
Appears in 1 contract
Samples: Income and Capital Tax Agreement