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Common use of RESIDENT Clause in Contracts

RESIDENT. (1) For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, legal 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 State.

Appears in 5 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, legal head officeplace 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 Contracting State, is liable to tax therein by reason of his domicile, residence, legal place of head or main office, place of management or any other criterion of a similar nature, and also includes that Contracting State and any political subdivision or local authority thereofthereof as well as a recognised pension fund of that Contracting State. This term, however, does not include any person who is liable to tax in that Contracting State in respect only of income from sources in that Contracting State.

Appears in 4 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 Contracting State, is liable to tax therein by reason of his domicile, residence, legal place of head office, place of management incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.

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, legal head officeplace 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 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 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, 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 Elimination 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 a person who, who is under the laws of that State, is liable to tax therein by reason of his domicile, residence, legal head officeplace 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, nature 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 3 contracts

Samples: Double Taxation Avoidance 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 domicile, residence, legal head officeplace of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

Appears in 3 contracts

Samples: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion, 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, legal head officeplace 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 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, legal head officeplace of management, place of management 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 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, 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: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion, 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, legal 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, 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 3 contracts

Samples: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, 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, legal head officeplace of management, place of management registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.

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 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, legal 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, 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 3 contracts

Samples: Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Mauritius for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Mauritius for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Mauritius 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, legal head officeplace of management, place of management incorporation or any other criterion of a similar nature, and . The term shall also includes include that State itself, its political subdivisions and any political subdivision or local authority thereofauthorities. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.

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, place of incorporation, residence, legal head office, place of management or any other criterion of a similar nature. However, and also includes that State and any political subdivision or local authority thereof. This term, however, this term does not include any person who is liable to tax in that State only in respect only of income from sources in that StateState or property situated therein.

Appears in 2 contracts

Samples: Double Taxation Agreement, Agreement for Avoidance of Double Taxation and 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 his domicile, residence, legal head officeplace 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 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: 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 that person’s domicile, residence, legal 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 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, legal head officeplace of incorporation or registration, 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 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, legal head officeplace of management, place of management incorporation or any other criterion of a similar nature, and . The term also includes the Government of that State itself, its political subdivisions and any political subdivision or local authority thereofauthorities. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.

Appears in 2 contracts

Samples: Agreement for the Avoidance of Double Taxation, 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 his domicile, residence, legal head officeplace 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 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, legal head officeplace 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: 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, legal head officeplace of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

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, legal head officeplace 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 his that person’s domicile, residence, legal head officeplace 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 State.

Appears in 2 contracts

Samples: 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 his domicile, residence, legal head officeplace of registration, place of management or any other criterion of a similar nature, and also includes that State and any political administrative-territorial subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources situated 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, legal head office, place of management or any other criterion teriterion 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, 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, legal head officeplace of effective management, 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, 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 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 officeplace of management, place of management incorporation or any other criterion of a similar nature, and also includes that State and any political or administrative subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income or capital gains from sources in that State.

Appears in 2 contracts

Samples: Double Taxation Agreement, 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, legal nationality, head office, place of management registration, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, 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, 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, legal head officeplace of incorporation, place of management or any other criterion of a similar nature, nature and also includes that State and any local authority or 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 his that person’s domicile, residence, legal head officeplace 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 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 State”means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, legal 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 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 his domicile, residence, legal head office, place of management or any other criterion of a similar nature, and also includes that State State, and any political administrative - territorial subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.

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 State”means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, legal place of head office, place of management incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

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, legal head officeplace of management, place of management incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

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, legal 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, 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, 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, legal head officeplace 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, 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, legal 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, However this term does not include any person who is liable to tax in that a Contracting State in respect only of income from sources in that State.

Appears in 2 contracts

Samples: Agreement Between the Republic of Indonesia and the Kingdom of Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Republic of Indonesia and the Kingdom of Belgium 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, legal head officeplace of incorporation, place of management or any other criterion of a similar nature, nature and also includes that State and any State, its political subdivision or and its local authority thereofauthority. 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 his domicile, residence, legal head office, 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: 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, legal head officeplace of management, place of management incorporation or any other criterion of a similar nature, and . The term shall also includes include that State itself, its political subdivisions and any political subdivision or local authority thereofauthorities. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that 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 his domicile, residence, legal head office, place of head office or effective management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

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, legal head office, place of management management, or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.

Appears in 2 contracts

Samples: Agreement for the Avoidance of Double Taxation, 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 his domicile, residence, legal head officeplace of management, place of management 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 law of that State, is liable to tax therein by reason of his domicile, residence, legal head officeplace of management, place of management registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources situated in that State.

Appears in 2 contracts

Samples: Double Taxation Agreement, 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 domicile, residence, legal head officeplace of management, place of management registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

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 the State, is liable to tax therein by reason of his domicile, residence, legal head officeplace of incorporation, place of management management, principle place of business or any other criterion of a similar nature, and also includes that State and any political subdivision or State, local authority thereof. This termor a statutory body thereof or, howeverin addition for Malaysia, does not include any person who is liable to tax in that State in respect only of income from sources in that Stateits political subdivision.

Appears in 1 contract

Samples: 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, legal head officedomicile, place of management 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 1 contract

Samples: 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 the State, is liable to tax therein by reason of his domicile, residence, legal head officeplace of incorporation, place of management management, principle place of business or any other criterion of a similar nature, and also includes that State and any political subdivision or State, local authority thereof. This termor a statutory body thereof or, howeverin addition for Malaysia, does not include any person who is liable to tax in that State in respect only of income from sources in that Stateits political subdivision.

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 domicile, residence, legal head officeplace of management, place of management registration, or any other criterion of a similar nature, and also includes that State and any political 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 1 contract

Samples: 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 in that State by reason reasons of his domicile, permanent residence, legal head office, place of management headquarters, or any other similar criterion of a similar natureand includes the State itself as well as its administrative bodies and local authorities. However, and also includes that State and any political subdivision or local authority thereof. This term, however, this term does not include any person who is liable to tax in that State in respect only by reasons of income from sources in that State or property situated 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 his domicile, residence, legal 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 State.

Appears in 1 contract

Samples: 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, legal 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 State.

Appears in 1 contract

Samples: 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, legal head officeduration 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 1 contract

Samples: 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 domicile, residence, legal head office, place of management or any other criterion of a similar nature, and also includes that Contracting State and any political subdivision or local authority 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 StateContracting State or capital situated therein.

Appears in 1 contract

Samples: 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, legal head officeplace 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 1 contract

Samples: 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, legal head officeplace of management, place of management registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, 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 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, legal 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: 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, legal 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, 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

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, legal head officeplace 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 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, legal head officeplace of management, place of management registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority authority, or statutory body thereof. This mis 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

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 place of management, head office, place of management registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, 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: 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, legal 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 situated in that State.

Appears in 1 contract

Samples: 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, legal head officeplace of incorporation, place of management 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 But this term shall not include any person who is liable to tax in that a Contracting State in respect only of income arising from sources in that State.

Appears in 1 contract

Samples: 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, who under the laws of that State, State is liable to tax therein by reason of his domicile, residence, legal head office, place of management 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 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 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 political-administrative subdivision, or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital 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" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, legal head officeplace 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: 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, legal head office, place of 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 StateState or capital situated therein.

Appears in 1 contract

Samples: 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, legal 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: 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, legal head officeplace of incorporation, place of management 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: 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, legal head officeplace of management, place of management 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

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, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereofthereof . 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: 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, legal head office, place of management or any other criterion of a similar nature, nature and also includes that State and any political political-administrative subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.

Appears in 1 contract

Samples: 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, legal head officeplace of management, place of management registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

Appears in 1 contract

Samples: 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, legal 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 thereofthereof as well as a recognised pension fund of that State. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.

Appears in 1 contract

Samples: 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, legal head officeplace 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 1 contract

Samples: Agreement for the Avoidance of Double Taxation

RESIDENT. (1) . For the purposes of this Agreement, the term "phrase “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, and also includes that State and any political subdivision or local authority thereof. This term, however, phrase 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 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, legal head office, place of management or any other criterion of a similar nature, and also includes that State and any political - administrative subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.

Appears in 1 contract

Samples: 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, legal head office, 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 termHowever, however, this term does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.

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 domicile, residence, legal head office, place of 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.

Appears in 1 contract

Samples: 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, legal 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 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 his domicile, residence, legal 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, However this term does not include any person who is liable to tax in that a Contracting State in respect only of income from sources in that State.

Appears in 1 contract

Samples: Agreement Between the Republic of Indonesia and the Kingdom of Belgium 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, legal head office, place of management or any other criterion of a similar nature, nature and also includes that State and any political subdivision sub-division 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: Agreement for Avoidance of Double Taxation and 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 his domicile, residence, legal head office, place of management or any other criterion of a similar nature, and also includes that State and any of its 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 1 contract

Samples: 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, legal head officeplace 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 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 the 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, 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 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, legal head officeplace of management, place of management registration or any other criterion of a similar nature, and also includes that State and any administrative-territorial or political subdivision subdivisions or local authority thereofauthority. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

Appears in 1 contract

Samples: 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, legal 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 autho- rity 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: Agreement Between the Government of the Grand Duchy of Luxembourg and the Government of the Republic of Botswana 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, legal head officeplace of incorporation, place of management or any other criterion of a similar nature, and also includes that State and State, any political subdivision or and any 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

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 officeplace 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 thereofthereof as well as a recognised pension fund of that State. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.

Appears in 1 contract

Samples: Ataf Model 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, legal head officeplace of incorporation, place of management effective management, place of registration or any other criterion of a similar nature, and also includes that State and any political subdivision or subdivision, local authority or administrative - territorial unit 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 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, legal 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 situated therein.

Appears in 1 contract

Samples: 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, legal 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 situated therein.

Appears in 1 contract

Samples: 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, legal head officeplace of incorporation (registration), place of effective management or any other criterion of a similar nature, and also includes that State and any political subdivision statutory body 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 situated therein.

Appears in 1 contract

Samples: Agreement for the Avoidance of Double Taxation

RESIDENT. (1) . For the purposes of this Agreement, the term "" resident of a Contracting StateState " means any person who, under the laws of that StateState , 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, 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: 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, legal head officeplace of incorporation, place of management management, or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.

Appears in 1 contract

Samples: 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, legal 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 State.

Appears in 1 contract

Samples: 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, legal head officeplace of management, place of management 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 his that person’s domicile, residence, legal head officeplace 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 1 contract

Samples: Double Taxation Agreement