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, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, subdivision or local authority thereof or any statutory body thereofbody. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, nature and also includes that State and any political subdivision, or administrative subdivision or local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and State, any political subdivision, local authority or a statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management management, place of registration or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 of this Article, an individual is a resident of both Contracting States, then his status shall be determined as followsin accordance with the following rules: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement. 3. Where by reason of the provisions of paragraph 1 of this Article a person other than an individual is a resident of both Contracting States, then the competent authorities shall endeavour to resolve the case by mutual agreement, due regard being had to its place of effective management or incorporation or to any other relevant criterion.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State State, a Land and any political subdivision, subdivision or local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 above an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under who is a resident of a Contracting State in accordance with the taxation laws of that State. The term includes the Government of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, a local authority or a statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is not a national of either State, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. (1. ) For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. (2. ) Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement. (3) Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident only of the State in which its place of effective management is situated.

RESIDENT. 1. For the purposes of this Agreement, Agreement the term "resident of a Contracting State" means means: (a) in the case of Singapore, any person whowho is resident in Singapore for its tax purposes; and (b) in the case of South Africa, under the laws of that State, any individual who is liable to tax therein by reason of his domicile, residence, ordinarily resident in South Africa and any other person which has its place of effective management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereofin South Africa. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has does not have a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any means: (a) in the case of Argentina, a person whowho is resident in Argentina for the purposes of Argentine tax; and (b) in the case of Malaysia, under a person who is resident in Malaysia for the laws purposes of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereofMalaysian tax. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, States then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; , if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement. 3. Where by reason of the provision of paragraph 1 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the State in which its place of effective management is situated.

RESIDENT. 1. For the purposes of this AgreementConvention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority in respect only of income from sources in that State or statutory body thereofcapital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivisionState, a local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management management, place of head office, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivisionState, a local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes purpose of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in respect only of income from sources in that State and any political subdivision, local authority or statutory body thereofState. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as followsfollows : (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, them he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any means: (a) in the case of Jordan, a person whowho is resident in Jordan for the purposes of Jordanian tax; and (b) in the case of Malaysia, under a person who is resident in Malaysia for the laws purposes of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereofMalaysian tax. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as followsin accordance with the following rules: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if . If he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement. 3. Where, by reason of the provisions of paragraph 1, a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the State in which its place of effective management is situated.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, nature and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting StateParty" means any person who, under the laws of that StateParty, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State Party and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting StatesParties, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State Party in which he has a permanent home available to him; if he has a permanent home available to him in both StatesParties, he shall be deemed to be a resident only of the State Party with which his personal and economic relations are closer (centre of vital interests); (b) if the State Party in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either StateParty, he shall be deemed to be a resident only of the State Party in which he has an habitual abode; (c) if he has an habitual abode in both States Parties or in neither of them, he shall be deemed to be a resident only of the State Party of which he is a national; (d) in any other case, the competent authorities of the Contracting States Parties shall settle the question by mutual 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 or any other criterion of a similar nature, and also includes that State and any political subdivision, subdivision or local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any means: (a) in the case of Malaysia, a person whowho is resident in Malaysia for the purposes of Malaysian Tax; and (b) in the case of Albania, under a person who is resident in Albania for the laws purposes of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereofAlbanian tax. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if . If he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with in which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other case, if he is a national of both States or of neither of them the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws taws of that State, is liable to tax therein by reason of his domicile, residence, place of head office, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, subdivision or local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement. 3. Where by reason of the provisions of paragraph I a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the State in which its head office is situated.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation or registration, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any means:-- (a) in the case of Thailand, a person whowho is resident in Thailand for the purposes of Thai tax; and (b) in the case of Malaysia, under a person who is resident in Malaysia for the laws purposes of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereofMalaysian tax. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as followsin accordance with the following rules: (a) he shall be deemed to be a resident only of the Contracting State in which he has a permanent home available to him; if . If he has a permanent home available to him in both Contracting States, he shall be deemed to be a resident only of the Contracting State with which his personal and economic relations are closer (centre of vital interests); (b) if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either Contracting State, he shall be deemed to be a resident only of the Contracting State in which he has an habitual abode; (c) if he has an habitual abode in both Contracting States or in neither of them, he shall be deemed to be a resident only of the Contracting State of which he is a national; (d) in any other caseif he is a national of both Contracting States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any State, a Land, a political subdivision, a local authority or a statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if . If he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the tax laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any a political subdivision, a local authority or and any statutory body or governmental agency thereof. However, in the case of a partnership or estate the term applies only to the extent that the income derived by such partnership or estate is subject to tax in that State as the income of a resident, either in its hands or in the hands of its partners or beneficiaries. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature. However, and also includes this term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein. The term "resident of a Contracting State" shall also include the Government of that State itself, its political subdivisions and local authorities and any agency or wholly-owned entity of such State, political subdivision, subdivision or local authority or statutory body thereofthat is established under the laws in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual 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 incorporation, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as followsfollows : (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to himhim ; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any means: (a) in the case of Mongolia, a person whowho is resident in Mongolia for the purposes of Mongolian tax; and (b) in the case of Malaysia, under a person who is resident in Malaysia for the laws purposes of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereofMalaysian tax. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as followsin accordance with the following rules: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if . If he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement. 3. Where, by reason of the provisions of paragraph 1, a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the State in which its place of effective management is situated.

RESIDENT. 1. For the purposes of this AgreementConvention, the term "resident of a Contracting State" means any person whoindividual who is ordinarily resident, under the laws of that State, is liable to tax therein by reason of or has his domicile, residence, place of management or any other criterion of a similar nature, and also includes her domicile in that State and any political subdivision, local authority company or statutory other body thereofof persons which has its place of effective management or incorporation in that State. 2. Where by reason of the provisions of paragraph 1 1, an individual is a resident of both Contracting States, then his or her status shall be determined as follows: (a) a. he or she shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he or she has a permanent home available to him or her; if he or she has a permanent home available to him or her in both States, he or she shall be deemed to be a resident only of the State with which his or her personal and economic relations are closer (centre of vital interests); (b) b. if the State in which he or she has his or her centre of vital interests cannot be determined, or if he or she has not a permanent home available to him or her in either State, he or she shall be deemed to be a resident only of the State in which he or she has an a habitual abode; (c) c. if he or she has an a habitual abode in both States or in neither of them, he or she shall be deemed to be a resident only of the State of which he or she is a national; (d) in any other cased. if he or she is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement. 3. Where, by reason of the provisions of paragraph 1, a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the State in which its place of effective management is situated. In case of doubt the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual 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 or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision, subdivision or local authority or a statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. (1. ) For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. (2. ) Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement. (3) Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident only of the State in which its place of effective management is situated.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of 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 incorporation, place of management, principal place of business or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he He shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if If the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if If he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in In any other case, the competent authorities of the Contracting States shall settle the question by mutual 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 and is resident thereof by reason of his domicile, residence, place of head or main office, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes purpose of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in respect only of income from sources in that State and any political subdivision, local authority or statutory body thereofState. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him [him] in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, them he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual 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 or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if . If he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting StateParty" means any person who, under the laws of that StateParty, is liable to tax therein by reason of his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and also includes that State Party and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting StatesParties, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State Party in which he has a permanent home available to him; if he has a permanent home available to him in both StatesParties, he shall be deemed to be a resident only of the State Party with which his personal and economic relations are closer (centre of vital interests); (b) if the State Party in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either StateParty, he shall be deemed to be a resident only of the State Party in which he has an habitual abode; (c) if he has an habitual abode in both States Parties or in neither of them, he shall be deemed to be a resident only of the State Party of which he is a national; (d) in any other case, the competent authorities of the Contracting States Parties shall settle the question by mutual agreement.

RESIDENT. (1. ) For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any State, a Land, a political subdivision, a local authority or a statutory body thereof. (2. ) Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting Con­ tracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement. (3) Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the State in which its place of effective management is situated.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision, subdivision or local authority or a statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests);interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode;abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national;national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

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 management or any other criterion of a similar nature, and also includes that State and State, any political subdivision, local authority or a statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) a. he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) b. if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) c. if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other cased. if he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement. 3. Where by reason of the provisions of paragraph 1 of this Article a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the State in which its place of effective management is situated.

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 incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, subdivision or local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "« resident of a Contracting State" State » means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, subdivision or local authority thereof or any statutory body thereofbody. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as followsfollows : (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, the term "resident ―resident of a Contracting State" State‖ means any person who, under the laws of that State, is liable to tax therein by reason of his that person’s domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, subdivision or local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his that individual’s status shall be determined as follows: (a) he the individual shall be deemed to be a resident only solely of the State in which he has a permanent home is available to himthe individual; if he has a permanent home is available to him the individual in both States, he the individual shall be deemed to be a resident only solely of the State with which his the individual’s personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests sole residence cannot be determineddetermined under the provisions of subparagraph (a), or if he has not a permanent home available to him in either State, he the individual shall be deemed to be a resident only solely of the State in which he the individual has an habitual abode; (c) if he the individual has an habitual abode in both States or in neither of them, he the individual shall be deemed to be a resident only solely of the State of which he the individual is a national; (d) in any other caseif the individual is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, . the term "‘resident of a Contracting State" means ” means: (a) in Seychelles, any person who, under the laws of that StateSeychelles, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion criteria of a similar nature, but this term does not include any person who is liable to tax in Seychelles in respect only of income from sources therein; (b) in South Africa, any individual who is ordinarily resident in South Africa and also includes any person other than an individual which has its place of effective management in South Africa; (c) that State and any political subdivision, subdivision or local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national;. (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management management, or any other criterion of a similar nature, and also includes that State and any political subdivision, subdivision or local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual 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 head office or place of effective management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the Contracting State in which he has a permanent home available to him; if he has a permanent home available to him in both Contracting States, he shall be deemed to be a resident only of the Contracting State with which his personal and economic relations are closer (centre of vital interests); (b) if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either Contracting State, he shall be deemed to be a resident only of the State in which which-he has an habitual abode; (c) if he has an habitual abode in both Contracting States or in neither of them, he shall be deemed to be a resident only of the Contracting State of which he is a national; (d) in any other caseif he is a national of both Contracting States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual 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 or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual a natural person is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre center of vital interests); (b) if the State in which he has his centre center of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) if the Contracting State in any other casewhich he is a resident cannot thus be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, the term "resident of a Contracting State" means any person who, under the laws law of that State, is liable to tax taxation therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as followsin accordance with the following rules: (a) he shall be deemed to be a resident only of the Contracting State in which he has a permanent home available to him; if . If he has a permanent home available to him in both States, he shall be deemed to be a resident only of the Contracting State with which his personal and economic relations are closer closest (hereinafter referred to as his "centre of vital interests"); (b) if the State in which he has his centre of vital interests cannot be determined, determined or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, them he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, the term "resident of a Contracting Stateone of the States" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

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 taxation therein by reason of his domicile, residence, place of management management, place of registration or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of the paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the Contracting State in which he has a permanent home available to him; if . If he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has does not have a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif each Contracting State considers him to be its national or if he is a national of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 1, an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of in which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual 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 or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, 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 management management, place of registration or any other criterion of a similar nature, and also includes that State and any political subdivision, subdivision or local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the Contracting State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has does not have a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a nationalcitizen; (d) in any other caseif his status cannot be determined according to sub-paragraphs "a" to "c", the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and State, any political or administrative subdivision, a local authority or a statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if . If he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and State, any political subdivision, local authority or a statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre center of vital interests); (b) if the State in which he has his centre center of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States State or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual 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 this domicile, residence, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 (1) an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he a. He shall be deemed to be a resident only of the State in which he has a permanent home available to him; if . If he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) b. if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) c. if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other cased. If he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement. 3. Where by reason of the provisions of paragraph (1) a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the state in which its place of effective management is situated.

RESIDENT. 1. For the purposes of this Agreement, the term "«resident of a Contracting State" » means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) a. he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) b. if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) c. if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) d. in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any means: (a) in the case of Malaysia, a person whowho is resident in Malaysia for the purposes of Malaysian tax; and (b) in the case of Uzbekistan, under a person who is resident in Uzbekistan for the laws purposes of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereofUzbekistan tax. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if . If he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests);interests)• (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, subdivisions or local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the Contracting State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means means: (a) in the case of Malta, a person who is resident in Malta for the purposes of Malta tax; and (b) in th e case of South Africa, any individual who is ordinarily resident in South Africa and any other person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, which has its place of effective management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereofin South Africa. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a no permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management head office, place of effective management, or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre center of vital interests); (b) if the State in which he has his centre center of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management residence or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority in respect only of income from sources in that State or statutory body thereofcapital situated therein. 2. Where If by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests)) ; (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management incorporation, place of registration or any other criterion of a similar nature, and also includes that State and any political subdivision, administrative subdivision or local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) if the status of the resident cannot be determined by reason of subparagraphs a) to c) in any other casethat sequence, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, the term "resident of a Contracting State" means any person whowhose income, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereof. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other case, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, Agreement the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason reasons of his domicile, residence, place of management or any other criterion of a similar nature. FBR, and also includes that State and any political subdivision, local authority or statutory body thereof.Government of Pakistan 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both Contracting States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual 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 or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this AgreementConvention, the term "resident of a Contracting State" means any person who, who under the laws law of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes circumstance. The term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereof. 2in respect only of income from sources in that State. 2nd Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he He shall be deemed to be a resident only of the State in which he has a permanent home available to him; if . If he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre center of vital interests);. (b) if the If it can not be determined State in which he has his centre center of vital interests cannot be determined, or if he is not in either State has not a permanent home available to him in either Statehim, he shall be is deemed to be a resident only of the State in which where he has an habitual abode;usually resides. (c) if he has an habitual abode in both States or if he does not reside permanently in neither of any them, he shall be deemed to be a resident only of the State of which state where he is a national;. (d) in if he is a national of both States or if he is not a citizen of any other caseof them, the competent authorities of the Contracting States shall settle the question by mutual agreementcoincidence.

RESIDENT. 1. For the purposes of this Agreement, Convention the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes . But this term does not include any person who is liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting StatesState, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a no permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an a habitual abode;. (c) if he has an a habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT. 1. For the purposes of this Agreement, Agreement the term "resident of a Contracting State" means means: (a) in the case of Singapore, any person whowho is resident in Si ngapore for its tax purposes; and (b) in the case of South Africa, under the laws of that State, any individual who is liable to tax therein by reason of his domicile, residence, ordinarily resident in South Africa and any other person which has its place of effective management or any other criterion of a similar nature, and also includes that State and any political subdivision, local authority or statutory body thereofin South Africa. 2. Where by reason of the provisions of paragraph para graph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has does not have a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual 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 (herein by reason of his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature. However, and also includes a person will not be deemed to be a resident of a contacting state by virtue only of his being liable to tax in that State and any political subdivision, local authority or statutory body thereofin respect of income from sources in that state. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests) ; b) if the State in which he has his centre of vital interests cannot be determined, he shall be deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

RESIDENT.  1. For the purposes of this Agreement, the term "”resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, subdivisions or local authority or statutory body thereof.  2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (o a) he shall be deemed to be a resident only of the Contracting State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); (o b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; (o c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; (o d) in any other caseif he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.