Where by reason of the provisions. of paragraph 1 a person is a resident of both Contracting States, then the competent authorities of the Contracting States shall determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this Convention.
Appears in 3 contracts
Samples: Double Taxation Agreement, Income Tax Convention, Convention for the Avoidance of Double Taxation
Where by reason of the provisions. of paragraph 1 a person an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall determine by mutual agreement through consultations the Contracting State of which that person individual shall be deemed to be a resident for the purposes of this ConventionAgreement.
Appears in 3 contracts
Samples: Income Tax Convention, Income Tax Convention, Income Tax Convention
Where by reason of the provisions. of paragraph 1 a person of this Article an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall determine by mutual agreement the Contracting State of which that person individual shall be deemed to be a resident for the purposes of this Convention.
Appears in 2 contracts
Samples: Double Taxation Treaty, Convention 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 the competent authorities of the Contracting States shall endeavour to determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this Convention, having regard to the place of its head or main office, its place of effective management and any other relevant factors.
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