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:
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 solely of the Contracting State in which its place of effective management or head office is situated. However, where such a person has its place of effective management in a Contracting State and its head office in the other Contracting State, the person shall be deemed to be a resident solely of that other State.
Where by reason of the provisions of paragraph. 1 an individual is a resident of both Parties, then his status shall be determined as follows:
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 asfollows :
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 solely of the Contracting State in which its place of effective management is situated. Permanent establishment
Where by reason of the provisions of paragraph. (1) a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Where by reason of the provisions of paragraph. 1 an individual is a resident of both Contracting States, his status shall be determined in accordance with the following rules: (a) he shall be deemed to be a resident 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 of the Contracting State with which his personal and economic relations are closest (hereinafter referred to as his "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 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 of the Contracting State of which he is a national; (d) if 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.
