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.
Appears in 14 contracts
Samples: Agreement for the Avoidance of Double Taxation, Income and Capital Tax Treaty, Convention for the Avoidance of Double Taxation
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 of the State in which its place of effective management is situated.
Appears in 9 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation
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.
Appears in 7 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, International Tax Agreements
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 Contracting State in which its place of effective management is situated.
Appears in 7 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
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 only of the State in which its place of effective management is situated.
Appears in 6 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
Where by reason of the provisions. of paragraph 1 a person other than an individual is a resident of both the Contracting States, then it he shall be deemed to be a resident of the State in which its his place of effective management is situated.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
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 of the Contracting State in which its place of effective management is situated. If its place of effective management cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 3 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation 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 State in which its place of effective management is situated.
Appears in 2 contracts
Samples: Double Taxation Agreement, Agreement Between the Republic of South Africa and the Federal Democratic Republic of Ethiopia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
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.
Appears in 2 contracts
Samples: Timor Sea Treaty, Timor Sea Treaty
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 Contracting State in which its place of effective management is situated.
Appears in 2 contracts
Samples: Double Taxation Agreement, Convention for the Avoidance of Double Taxation
Where by reason of the provisions. of paragraph 1 (1) of a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the Contracting State in which its place of effective management is situated.
Appears in 2 contracts
Samples: Double Taxation Agreement, Agreement for Avoidance of Double Taxation
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 of the State in which its place of effective management is situatedituated.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
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 is situated.
Appears in 2 contracts
Samples: International Tax Agreements, Double Taxation Avoidance Agreement
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.
Appears in 2 contracts
Samples: Timor Sea Treaty, Timor Sea Treaty
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 Contracting State in which the control and management of its place of effective management business is situatedexercised.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 of the Contracting State in which its place of effective management is situated.
Appears in 1 contract
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 only of the Contracting State in which its place of effective management is situated.
Appears in 1 contract
Where by reason of the provisions. of paragraph 1 a person other than an individual is a resident of both Contracting A 368 Attachments States, then it shall be deemed to be a resident only of the State in which its place of effective general management is situated.
Appears in 1 contract
Samples: Employment Contract
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 Contracting State in which its place of effective management is situated.
Appears in 1 contract
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 is situated.
Appears in 1 contract
Samples: International Tax Agreements
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.
Appears in 1 contract
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 of the Contracting State in which its place of effective management is situated.
Appears in 1 contract
Samples: Double Taxation Agreement
Where by reason of the provisions. of paragraph 1 (1), a person other than an individual is a resident of both the Contracting States, then it shall be deemed to be a resident of the Contracting State in which its place of effective management is situated.
Appears in 1 contract
Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
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 head office is situated.
Appears in 1 contract
Where by reason of the provisions. of paragraph 1 1, a person other than an individual is regarded as 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.
Appears in 1 contract
Where by reason of the provisions. of paragraph 1 1, a person other than an individual is a resident 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.
Appears in 1 contract
Samples: Double Taxation Agreement
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 of the State in which its place of effective management is situated.
Appears in 1 contract
Samples: Agreement for Avoidance of Double Taxation and the Prevention of Fiscal Evasion
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 Contracting State in which its place of effective management is situated.
Appears in 1 contract
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 Contracting State in which its place of effective management is situated. If the place of effective management cannot be determined, then it shall be deemed to be a resident of the Contracting State in which its registered offices are situated.
Appears in 1 contract
Samples: Income and Capital Tax Convention
Where by reason of the provisions. of paragraph 1 a person other than an individual is deemed a resident of both Contracting States, then it shall be deemed to be a resident of the Contracting State in which its place of effective management is situated. This provision shall apply to partnerships as well as to companies deemed partnerships which have been founded and organized in accordance with the laws of Contracting State.
Appears in 1 contract
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.
Appears in 1 contract
Samples: Double Taxation Agreement
Where by reason of the provisions. of paragraph 1 (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.
Appears in 1 contract
Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
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 only of the Contracting State in which its place of effective management is situated.
Appears in 1 contract