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.
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Samples: www.legislation.gov.au, www.legislation.gov.au
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 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.
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Samples: www.revenue.ie
Where by reason of the provisions of paragraph. (1) 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.
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Samples: www.spenceclarke.com
Where by reason of the provisions of paragraph. (1) 1 a person other than an individual or a company is a resident of both Contracting States, then it shall then 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.
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Samples: Double Tax Agreement
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 only 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.
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Samples: Agreement
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 If its place of effective management in a Contracting State and its head office in the other Contracting Statecannot be determined, the person competent authorities of the Contracting States shall be deemed to be a resident solely of that other Statesettle the question by mutual agreement.
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Samples: Agreement