Common use of RESIDENT Clause in Contracts

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management management, place of incorporation or any other criterion of a similar nature. The term nature and also includes the Government of that Contracting State and a any local authority thereof. But the 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 thereinState.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management management, place of incorporation or any other criterion of a similar nature. The term shall also includes include the Government of that Contracting State and or a local authority thereof. But the 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.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income and capital gains from sources in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this Convention, 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, place of registration or incorporation, residence, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any administrative subdivision, central or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that Contracting State in respect only of income from sources in that State or capital situated thereinContracting State.

RESIDENT. 1. For the purposes of this Convention, 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, place of incorporation, residence, place of management management, or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the this term does not include any person who is liable to tax in that State in respect only of income from sources situated in that State or capital situated therein.

RESIDENT. 1. For the purposes of this 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 as a resident of his domicilethat State, place of incorporation, residence, place of management or any other criterion of a similar nature. The term and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein as a resident of that State or is liable to tax by reason of his domicile, place of incorporation, residencemanagement, place of management incorporation or any other criterion of a similar nature. The term , and also includes the Government that State and any political subdivision or local authority thereof as well as a recognised pension fund of that Contracting State and a local authority thereofState. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this 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 incorporation, residenceregistration, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the 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 thereinState.

RESIDENT. 1. For the purposes of this Convention, the term "“resident of a Contracting State" means ” refers to any person who, under the laws of that State, is liable to tax therein by reason of his or her domicile, place of incorporation, residence, place of management headquarters or any other criterion of a similar nature. The term nature and also includes the Government of that Contracting State itself and a any political subdivisions or local authority thereofentities. But the term This term, however, does not include any person persons who is are liable to tax in that State in respect only of income from sources in that said State or capital situated therein, or from capital located in the same.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein in that State by reason of his domicile, residence, place of incorporation, residence, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any local authority authorities thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this ConventionAgreement, the term "«resident of a Contracting State" » means any person who, under the laws of that Contracting State, is liable to tax therein by reason of his domicile, residence, place of incorporation, residenceregistration, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any political subdivision, central or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that Contracting State in respect only of income from sources in that State or capital situated thereinContracting State.

RESIDENT. 1. For the purposes of this 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 incorporation, residenceregistration, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any administrative-territorial subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

RESIDENT. - 1. ) For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the this term does not include any person who is liable to tax in that State in respect only of income from sources situated in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person whowhose income or capital, under the laws of that State, is liable to tax therein by reason of his domicile, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the 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.

RESIDENT. 1. For the purposes of this Convention, Agreement the term terms "resident of a Contracting State" means and "resident of the other Contracting State" mean any person who, under the laws of that Contracting State, is liable to tax taxation therein by reason of his domicileresidence, permanent abode, place of incorporation, residence, place of management registration or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term This term, however, does not include any person who is liable to tax in that a Contracting State only in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For 1.For the purposes of this Convention, 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the 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 thereinState.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the 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.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management management, place of incorporation or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income or capital gains from sources in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this ConventionAgreement, the term "resident of 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, residenceincorporation or registration, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a local authority any political subdivision thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, State is liable to tax therein in that State by reason of his domicile, residence, place of incorporation, residence, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any administrative subdivision or local authority thereof. But the term ; This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax taxation therein by reason of his the person's domicile, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term nature but 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 thereinState.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that Contracting State, is liable to tax therein by reason of his domicile, residence, place of incorporation, residence, place of management head or main office or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the this term does not include any person who is liable to tax in that Contracting State in respect only of income from sources in that State or capital situated thereinContracting State.

RESIDENT. § 1. For the purposes of this ConventionAgreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the 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.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the this term does not include any person who is liable to tax in that State in respect only of income from sources situated in that State or capital situated thereinState.

RESIDENT. (1. ) For the purposes of this Convention, Agreement‚ the term "”resident of a Contracting State" ” means any person who, ‚ under the laws of that State, ‚ is liable to tax therein by reason of his that person’s domicile, place of incorporation, ‚ residence, ‚ place of management or any other criterion of a similar nature. The term ‚ and also includes the Government of that Contracting State itself‚ a Land and a any political subdivision or local authority thereof. But the term This term‚ however‚ does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this ConventionAgreement, the term "resident of 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, residence, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any of its political subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management head or main office, place of management, place of incorporation or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this ConventionAgreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, place of incorporation, residence, place of management management, or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the this term does not include any person who is liable to tax in that State state in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this 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 incorporation, residence, place of management or any other criterion of a similar nature. The term nature and also includes the Government of that Contracting State and a any local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management management, place of registration or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. § 1 For the purposes of this 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 incorporation, residence, place of management or any other criterion of a similar nature. The term nature and also includes the Government of that Contracting State and a any local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this 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 that person's domicile, place of incorporation, residence, place of management management, place of incorporation or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this Convention, 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, place of incorporation, residence, place of management or any other criterion of a similar naturecircumstance. The term also includes the Government of that Contracting State and a local authority thereof. But the term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.State. 2nd Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status as follows:

RESIDENT. 1. For the The purposes of this Convention, the term "resident of a Contracting State" means any person whowho , under the laws law of that StateState , is liable to tax therein by reason of his domicile, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the However, this term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

RESIDENT. 1. For 1.For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management management, place of incorporation or any other criterion of a similar nature. The term nature and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or of capital situated therein.

RESIDENT. 1. For the purposes of this 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 incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the 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 shall also include the government of a Contracting State or a local authority thereof, or any agency or instrumentality of any such government or authority.

RESIDENT. 1. For the purposes of this Convention, 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 or main office, place of incorporation, residence, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that Contracting State in respect only of income from sources in that State or capital situated therein.Contracting State

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that Contracting State, is liable to tax therein by reason of his domicile, residence, place of incorporation, residencehead or main office, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a local authority thereof. But the term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.includes:

RESIDENT. 1. l. For the purposes of this 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, place of incorporation, residence, place of management registration or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the 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.

RESIDENT. 1. For the purposes of this 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 has in that State his domicile, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this ConventionAgreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, place of incorporation, residence, place of management or any other criterion of a similar nature. The This term also includes the Government of that Contracting State and a local authority thereof. But the term however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital property situated therein.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this Convention, 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the 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 thereinState.

RESIDENT. 1. For the purposes purpose of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature; it also means, in the case of Belgium, companies (other than companies with share capital) which have elected to have their profits subjected to the individual income tax. The term also includes the Government of that Contracting State and a local authority thereof. But the However this term does not include any person who is liable to tax in that a Contracting State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this ConventionAgreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this 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 that person’s domicile, place of incorporation, residence, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income or capital gains from sources in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to income tax therein by reason of his domicile, residence, place of incorporation, residence, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any administrative-territorial subdivisions or local authority thereofauthority. But the 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 property situated therein.

RESIDENT. 1. For the purposes of this Convention, the term "“resident of a Contracting State" means ” refers to any person who, under the laws of that State, is liable to tax therein by reason of his domicile, place of incorporation, residence, place of management management, or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the However, this term does not include any person who is liable to tax in that State in respect only of income derived from sources in that State or from capital situated thereinlocated in the same.

RESIDENT. 1. For the purposes of this ConventionAgreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, place of incorporation, residence, place of management residence or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the 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.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this ConventionAgreement, 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, place of incorporation, residence, place of effective management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the 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 thereinState.

RESIDENT. 1. For the purposes of this 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 that person’s domicile, place of incorporation, residence, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein there- in by reason of his domicile, residence, place of incorporation, residence, place of management man- agement or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

RESIDENT. 1. For the The purposes of this Convention, the term "resident of a Contracting State" means any person whowho , under the laws law of that StateState , is liable to tax therein by reason of his domicile, place of incorporationresidence, residenceregistered office , place of management or any other criterion of a similar nature, this term includes the state itself and its political subdivisions or local authorities. The term also includes the Government "resident of that a Contracting State " includes partnerships and a local authority thereof. But the term does not include any person who other groups of persons whose place of management in that State and each member is personally liable to tax in for its share of the profits under the domestic laws of that State in respect only of income from sources in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this 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 nationality, domicile, residence, place of management, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the 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.

RESIDENT. 1. For the purposes of this ConventionAgreement, the term "resident of a Contracting State" means any person who, who under the laws of that State, is liable to tax therein by reason of his domicile, place of incorporation, residence, place of management effective management, place of incorporation or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the 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 thereinstate.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a or any local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this 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 incorporation, residenceincorporation of a legal person by registration, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management management, place of incorporation or any other criterion of a similar nature. The term shall also includes include the Government of that Contracting State and or a local authority thereof. But the this term does not include any person who is liable to tax in that Contracting State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term nature and also includes the Government of that Contracting State and a any political subdivision or local authority thereofor administrative - territorial unit. But the 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.

RESIDENT. 1. For the purposes of this 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 incorporation, residence, place of management or any other criterion of a similar nature. The term nature and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management registration or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the , but this term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital property situated therein.

RESIDENT. 1. For the purposes of this 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 the person's domicile, place of incorporation, residence, place of management management, place of incorporation or any other criterion of a similar nature. The term nature and also includes the Government of that Contracting State and a any political subdivision or local authority thereofthereof or any agency or instrumentality of any such subdivision or authority. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this Convention, 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 incorporation, residenceregistration, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax taxation therein by reason of his domicile, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the This term does not include include, however, any person who is liable to tax taxation in that State in respect only of income from sources in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management management, place of incorporation or any other criterion of a similar nature. The term shall include also includes the Government of that a Contracting State and State, a political subdivision or local authority thereof, or an agency of such Government, subdivision or authority. But the 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.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the this term does not include any person who is liable to tax in that in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this the present Convention, the term "expression “resident of a Contracting State" means ” designates any person whothat, under by virtue of the laws legislation of that this State, is liable subject to tax therein taxation in this State by reason of his this person's domicile, place of incorporation, residence, place of management or any other criterion criteria of a similar an analogous nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term However, this expression does not include any person who is liable those persons that are subject to tax in that this State in respect only of for income from sources situated in that this State or for capital situated thereinthere.

RESIDENT. 1. For the purposes of this ConventionAgreement, 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the However, this term does not include any person the residents who is are liable to tax in that State only in respect only of income from sources in that State or capital properties situated thereinin that State.

RESIDENT. 1. a) For the purposes of this Convention, 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, place of incorporation, residence, place of management management, place of incorporation or other similar circumstances. And also includes that State and any other criterion of a similar naturepolitical subdivision or local authority. The term also includes the Government of that Contracting State and a local authority thereof. But the term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinonly of income as is attributable to a permanent establishment in that State.

RESIDENT. 1. For the purposes of this Convention, Convention the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax taxation therein by reason of his domicile, residence, place of incorporation, residenceregistration, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. - 1. ) For the purposes of this 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, place of incorporation, residence, place of management management, place of incorporation or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the 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.

RESIDENT. 1. For the purposes of this ConventionAgreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, place of incorporation, residence, place of management management, place of registration, place of incorporation or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the 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.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable subject to tax therein by reason of his domicile, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to income tax therein by reason of his domicile, place of incorporation, residence, place of management management, place of incorporation or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any political or administrative subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this 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 incorporation, residence, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws law of that State, State is liable to tax therein taxes in that State by reason of his domicile, place of incorporation, residence, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any administrative subdivision or local authority authorities thereof. But the term ; This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this ConventionAgreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, place of incorporation, residence, place of management management, place of incorporation or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this Convention, 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the this term does not include any person who is liable to tax in that State in respect only of income from sources situated in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. - 1. ) For the purposes of this Convention, 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereofnaturs. But the this term does not include any person who is liable to tax in that State in respect only of income from sources situated in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person whowhose income or capital, under the laws of that State, is liable subject to tax therein by reason of his domicile, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this Convention, 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, place of incorporation, residence, place of management head or main office, main object of the activity, place of management, or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the 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 thereinState.

RESIDENT. 1. For the purposes of this ConventionAgreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable Iiable to tax therein in that State by reason of his that person's domicile, place of incorporation, residence, place of management incorporation or registration, place of management, or any other criterion of a similar nature. The term , and also includes the Government that State or any political subdivision or local authority of that Contracting State and a local authority thereofState. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in inn that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this Convention, the term "expression “resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term However, this expression does not include any person persons who is are liable to tax in this State only on income that State in respect only of income they derive from sources situated in that State or for capital situated thereinthat they own in that State.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management management, place of incorporation or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State State, any political subdivision and a any local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term nature and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

RESIDENT. - 1. ) For the purposes of this Convention, 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, place of incorporation, residence, place of management management, or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the 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.

RESIDENT. 1. For the purposes of this 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 incorporation, residence, place of management or any other criterion of a similar nature. The term , and also includes the Government that State and any political subdivision or local authority thereof as well as a recognized pension fund of that Contracting State and a local authority thereofState. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. But the term This term, however does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management management, place of incorporation or any other criterion of a similar nature. The term , and also includes the Government of that Contracting State and a any local authority thereof. But the term This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

RESIDENT. 1. For the purposes of this 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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term nature and also includes the Government of that Contracting State and a any political subdivision or local authority thereof. But the term This term, however does not include any person who is liable to tax in that State in respect only of income or capital gains from sources in that State or capital situated thereinState.