Where by reason of the provisions. of paragraph 1 an individual is a resident of both Contracting States, then his case 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 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 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, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
Where by reason of the provisions. of paragraph 1 1, an individual is a resident of both Contracting States, then his case status shall be determined in accordance with the following rulesas follows:
(a) he shall be deemed to be a resident 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 of the Contracting State with which his personal and economic relations are closer (hereinafter referred to as his "centre of vital interestsβ);
(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, the competent authorities of the two Contracting States shall settle the question by mutual agreement.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
Where by reason of the provisions. of paragraph 1 an individual is a resident of both Contracting States, then his case status shall be determined in accordance with the following rulesas follows:
(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 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 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, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
Where by reason of the provisions. of paragraph 1 an individual is a resident of both Contracting States, then his case 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 closer closest (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, the competent authorities of the Contracting States shall settle the this question by mutual agreement.
Appears in 2 contracts
Samples: Agreement for the Elimination of Double Taxation, Agreement for the Elimination of Double Taxation
Where by reason of the provisions. of paragraph 1 an individual is a resident of both Contracting States, then his case status shall be determined in accordance with the following rulesas follows:
(a) he 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 closer closest (centre of vital interests);
(b) if 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 If he has an habitual abode in both Contracting States or in neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Where by reason of the provisions. of paragraph 1 an individual is a resident of both Contracting States, then his this case shall be determined in accordance with the following rules:
(a) he 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 closer closest (centre of vital interests);
(b) if 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 a habitual abode;
(c) if If he has an a habitual abode in both Contracting States or in neither of them, the competent authorities he shall be deemed to be a resident of the Contracting States shall settle the question by mutual agreementState of which he is a national.
Appears in 1 contract
Samples: Income and Capital Tax Convention
Where by reason of the provisions. of paragraph 1 an individual is a resident of both Contracting States, then his case status shall be determined in accordance with the following rules:
as follows: (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 closer closest (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, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
Where by reason of the provisions. of paragraph 1 an individual is a resident of both Contracting States, then his case status shall be determined in accordance with the following rules:
(a) he 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 arc closer (centre of vital interests.);
(b) if 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 c. If he has an habitual abode in both bath 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.
Appears in 1 contract
Samples: Double Taxation Agreement
Where by reason of the provisions. of paragraph 1 an individual is a resident of both Contracting States, then his case status shall be determined in accordance with the following rulesas follows:
(a) he shall be deemed to be a resident 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 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 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, the competent authorities of the Contracting States shall settle the question by mutual agreement.mutual
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
Where by reason of the provisions. of paragraph 1 an individual is a resident of both Contracting States, then his case status shall be determined in accordance with the following rulesas follows:
(a) 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 closer (centre of vital interests);
(b) 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) c. if he has an habitual abode in both Contracting States or in neither of them, the competent authorities of the two Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement