RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature. 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, place of incorporationmanagement, place of effective management incorporation or any other criterion of a similar nature. This termThe term shall also include that State itself, however, its political subdivisions and local authorities. 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, 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 situated 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 his that person’s domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that Contracting State and any political subdivision or local authority thereof as well as a recognised pension fund of that Contracting State. This term, however, does not include any person who is liable to tax in that Contracting State in respect only of income from sources in that Contracting State.
Appears in 3 contracts
Samples: Agreement for the Elimination of Double Taxation, Double Tax Agreement, Agreement for the Elimination of Double Taxation
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management, place of incorporation, place of effective management registration or any other criterion of a similar nature. 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, 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 Contracting State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State and any political subdivision 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, 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 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 person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State and any political subdivision 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, place of incorporation, place of effective management or any other criterion of a similar nature. 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, place of incorporationmanagement, place of effective management registration or any other criterion of a similar nature. 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 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, place of incorporation, place of effective management or any other criterion of a similar nature. 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, place of incorporation, place of effective management or any other criterion of a similar naturenature 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 that person’s 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 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, place of incorporation, place of effective 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, place of incorporationregistration, place of effective management or any other criterion of a similar nature, and also includes that State and any 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 law of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationmanagement, place of effective management registration or any other criterion of a similar nature. 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 of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature. 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, place of incorporation, place of effective management or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in and also includes that State in respect only of income from sources in that Stateand any political subdivision, local authority or statutory body thereof.
Appears in 2 contracts
Samples: Double Taxation Agreement, Agreement for the Elimination of Double Taxation
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in and also includes that State, a local authority or statutory body thereof.
Appears in 2 contracts
Samples: Double Taxation Agreement, Double Taxation Avoidance Agreement
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his that person’s 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 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 any person who, under the laws of that State, is liable to tax therein by reason of his domicile, place of incorporation, residence, place of incorporation, place of effective management or any other criterion of a similar nature. This termHowever, 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, place of incorporationnationality, head office, place of effective management registration, place of incorporation or any other criterion of a similar nature. 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, place of incorporation, place of effective management or any other criterion of a similar naturenature and also includes that State and any local authority or political subdivision thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that Contracting State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of head office or effective management or any other criterion of a similar nature. 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, place of incorporation, place of effective management or any other criterion of a similar naturenature and also includes that State, its political subdivision and its local authority. 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, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State 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 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 purpose of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature. 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 State.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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, place of incorporationmanagement, 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 and the Prevention of Fiscal Evasion
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, place of incorporationhead office, place of effective management incorporation or any other criterion of a similar nature. 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, place of incorporationmanagement, place of effective 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, place of incorporation, place of effective management or any other criterion of a similar nature. 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, place of incorporation, place of effective management or any other criterion of a similar nature. 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 State”means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationhead office, place of effective management or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State, and any 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 purpose of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature. 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 2 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
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationregistration, place of effective management or any other criterion of a similar naturenature and also includes that State 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, place of incorporationmanagement, place of effective management incorporation or any other criterion of a similar nature. 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 that person’s 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 State.
Appears in 2 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationincorporation or registration, place of effective management or any other criterion of a similar nature, and also includes that State 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 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. (1. ) For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationmanagement, place of effective management registration or any other criterion of a similar nature. 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 Avoidance Agreement
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature. 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: Double Taxation Avoidance Agreement
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationmanagement, place of effective management or any other criterion of a similar nature. 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: Double Taxation Avoidance Agreement
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationmanagement, place of effective management or any other criterion of a similar nature. 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 1 contract
RESIDENT. 1. For the purposes of this Agreement, the term “''resident of a Contracting State” '' means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar naturenature 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 his domicile, residence, place of incorporationmanagement, place of effective management registration or any other criterion of a similar naturenature and also includes that State and any other 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
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature. 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 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 situated in that State.
Appears in 1 contract
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management management, or any other criterion of a similar nature. 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
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar naturenature , and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income or capital gains from sources in that State, or capital situated therein.
Appears in 1 contract
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationmanagement, head office, place of effective management registration or any other criterion of a similar nature, and also includes that State 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
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State 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 his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationhead or main office, place of effective management or any other criterion of a similar naturenature 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 his domicile, residenceresi- dence, place of incorporation, place of effective management or any other criterion of a similar naturenature 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 1 contract
Samples: Double Tax Agreement
RESIDENT.
1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, State is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationmanagement, place of effective 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 domicile, residence, place of incorporationmanagement, place of effective management incorporation or any other criterion of a similar nature, and also includes that State and any 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
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature. This term, however, does But this term shall not include any person who is liable to tax in that State in respect only of income from sources in that State.
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, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State 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 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, place of incorporationmanagement, place of effective management incorporation or any other criterion of a similar nature, and also includes that State and any administrative subdivision or local authority thereof, as well as an investment fund established 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 1 contract
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationmanagement, place of effective management registration, or any other criterion criteri- on 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
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management mamagement 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 ane 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 his domicile, residence, place of incorporationhead office, place of effective management incorporation or any other criterion of a similar nature. 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 his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in and also includes that State, any political subdivision, local authority or a statutory body thereof.
Appears in 1 contract
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationmanagement, place of effective management registration or any other criterion of a similar nature, and also includes that State 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
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar naturenature 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
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws and regulations of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in and also includes that State, any political subdivision, local authority or a statutory body thereof.
Appears in 1 contract
Samples: Agreement for the Avoidance of Double Taxation and the Prevention of Tax Evasion
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State and any 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 arising from sources in that State.
Appears in 1 contract
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State or its local authorities. 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, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management management, principal place of business or any other criterion of a similar nature, and also includes that State 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
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationregistration, place of effective management management, place of incorporation or any other criterion of a similar nature, and also includes that State 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: Double Taxation Agreement
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State and 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 the State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management management, principle place of business or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in and also includes that State, local authority or a statutory body thereof or, in addition for Malaysia, its political subdivision.
Appears in 1 contract
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationdomicile, place of effective 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 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 the State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management management, principle place of business or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in and also includes that State, local authority or a statutory body thereof or, in addition for Malaysia, its 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, place of incorporationmanagement, place of effective management registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local 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
RESIDENT.
1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State 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
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, place of incorporationmanagement, place of effective management incorporation or any other criterion of a similar nature, and also includes that State and any administrativeterritorial 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 1 contract
RESIDENT. 1. For the purposes of this Agreement, the term “‘resident of a Contracting State” ’ means any person who, under the laws of that State, is liable to tax therein by reason of his that person’s domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State 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: Ataf Model Tax Agreement
RESIDENT. (1. ) For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationmanagement, place of effective management incorporation or any other criterion of a similar nature. The term also includes the Government of that State itself, its political subdivisions and local authorities. 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 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, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar naturenature and also includes that State and any political 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 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, place of incorporationmanagement, place of effective management registration or any other criterion of a similar nature, and also includes that State 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 that person’s domicile, residence, place of incorporationlegal 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: Double Taxation Agreement
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State and any political subdivision or 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: Double Taxation Agreement
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State and any political 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, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective 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 domicile, residence, place of incorporationlegal 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
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management 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
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State, any political 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, place of incorporation, place of effective management or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in and also includes that State in respect only of income from sources in that Stateand any political subdivisions or local authority thereof.
Appears in 1 contract
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 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, place of incorporation, place of effective management or any other criterion of a similar nature. 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
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State 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 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 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 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 purpose of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationmanagement, place of effective management registration or any other criterion of a similar nature. 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 AgreementConvention, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management, place of incorporation, place of effective management registration or any other criterion of a similar nature. 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.and also includes:
Appears in 1 contract
Samples: Double Taxation 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 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 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
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationmanagement, place of effective management incorporation or any other criterion of a similar nature, and also includes that State and any territorial-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 1 contract
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationeffective management, place of effective management incorporation or any other criterion of a similar nature. 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: Double Taxation Agreement