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 485 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, 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 it shall be deemed to be a resident only of the State in which its place of effective management is situated.
Appears in 202 contracts
Samples: Convention for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, 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 only of the 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 97 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Agreement for the Elimination 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 Contracting State in which its place of effective management is situated.
Appears in 83 contracts
Samples: Convention for the Avoidance of Double Taxation, Agreement Between the Government of the Republic of Indonesia and the Government of the People's Republic of Bangladesh for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, 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 only of the State in which its place of effective management is situated.
Appears in 62 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, 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 only of the State in which its place of effective management is situated.
Appears in 27 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, 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 only of the Contracting State in which its place of effective management is situated.
Appears in 26 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 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident only solely of the State in which its place of effective management is situated.
Appears in 23 contracts
Samples: Convention for the Avoidance of Double Taxation, 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 only of the State in which its place of effective management is situated.
Appears in 22 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, 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 it shall be deemed to be a resident only of the 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 21 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Agreement, 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 only of the Contracting State in which its place of effective management is situated.
Appears in 20 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, 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 only 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 19 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Agreement, Double Taxation Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual indi- vidual 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 17 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, 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 it shall be deemed to be a resident only solely of the Contracting State in which its place of effective management is situated.
Appears in 12 contracts
Samples: International Tax Agreements, 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 only of the Contracting State in which its place of effective management head office is situated.
Appears in 10 contracts
Samples: Double Taxation Agreement, Agreement for Avoidance of Double Taxation of Income, Agreement for Avoidance of Double Taxation of Income
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 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 9 contracts
Samples: Agreement for the Avoidance of Double Taxation, 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 Contracting States, then it shall be deemed to be a resident only of the State in which its place of effective management it is situatedmanaged and controlled.
Appears in 9 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, 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 it shall be deemed to be a resident only 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 8 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 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 head or main office is situated.
Appears in 8 contracts
Samples: Agreement for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, 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 only of the State in which its place of effective management is situated. In case of doubts the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 8 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Agreement, Double Taxation Avoidance 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 only of the State in which its place of effective management incorporation is situated.
Appears in 8 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 herein, 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 8 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, 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 it shall be deemed to be a resident only of the Contracting State in which its place of head office or place of effective management is situated. However, where such a person has its place of effective management in a Contracting State and its place of head office in the other Contracting State, the competent authorities of the Contracting States shall by mutual agreement determine the State of which the person in question is a resident.
Appears in 7 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Agreement, 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 only of the State in which its place of effective management is situated. If the State in which its place of effective management is situated cannot be determined, then the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 7 contracts
Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion, 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 only of the State in which its place of effective management is situated.. In case of doubts the competent authorities of the Contracting States shall settle the question by mutual agreement. --------------------------------------------------------------------------------
Appears in 7 contracts
Samples: Convention for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, 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 it shall be deemed to be a resident only of the Contracting State in which its place of effective management is situated.
Appears in 7 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, 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 only of the State in which its place of effective management is situated. If the State in which its place of effective management is situated cannot be determined, then the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 6 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 herein, 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 or head office 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 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. 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 6 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement 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 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 head office is situated.
Appears in 6 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Income 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 he shall be deemed to be a resident only of the State in which its his place of effective management is situated.
Appears in 5 contracts
Samples: Double Taxation Agreement, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion, 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 only of the Contracting State in which its place of effective management is situated.
Appears in 5 contracts
Samples: Income Tax Treaty, Double Taxation Avoidance Agreement, 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 only solely of the Contracting State in which its place of effective management it is situatedincorporated, created or organized.
Appears in 5 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation, 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 only of the State in which its place of effective management is situated. If the place in which its place of effective management is situated cannot be determined, then the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement.
Appears in 5 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Botswana Ireland 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 only of the State in which its place of effective management is situated.
Appears in 5 contracts
Samples: Agreement for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, 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 it shall be deemed to be a resident only of the State in which its place of effective management is situated.
Appears in 5 contracts
Samples: Agreement Between the Republic of Indonesia and the Kingdom of Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Republic of Indonesia and the Kingdom of Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Republic of Indonesia and the Kingdom of Belgium 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 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. If the State in which its place of effective management is situated cannot be determined, then the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement.
Appears in 5 contracts
Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion, Double Taxation Agreement, Agreement for the 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 the 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 5 contracts
Samples: Double Taxation Agreement, Double Taxation Avoidance Agreement, Double Taxation Avoidance 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 only of the 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. In the absence of such agreement, such person shall not be considered to be a resident of either Contracting State for purposes of enjoying benefits under the Agreement.
Appears in 5 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 paragraphs 1 and 2 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 4 contracts
Samples: Convention for the Avoidance of Double Taxation, Income and Capital Tax Convention, Convention for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual 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. If the State in which its place of effective management is situated cannot be determined, then the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement.
Appears in 4 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation, 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 only of the State in which its place of effective management is situated. If its place of management cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 4 contracts
Samples: Agreement for the Avoidance of Double Taxation, Income Tax Agreement, Double Taxation Avoidance 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 only of the State in which its place of effective management is situated. If the State in which its place of effective management is situated cannot be determined, then the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 4 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Agreement, Income Tax 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 4 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, 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 it shall be deemed to be a resident only of the State in which its place of effective management it is situatedincorporated.
Appears in 4 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 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 situatedwhere it was incorporated (registered).
Appears in 4 contracts
Samples: Income Tax Treaty, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 above 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 4 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Avoidance 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 only of the State in which its place of effective management is situated.
Appears in 4 contracts
Samples: Income Tax Treaty, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement 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 1, a person other than an individual is a resident of both Contracting States, then it such person shall be deemed to be a resident only of the State in which its place of effective management is situatedlocated.
Appears in 3 contracts
Samples: Convention for the Avoidance of Double Taxation, Income and Capital Tax Convention, Income and Capital Tax Convention
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 3 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, 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 it shall be deemed to be a resident only of the State in which its place of effective management is situated. If the place of effective management cannot be determined, then the Competent Authorities 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 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. However, where such person has its place of effective management in one of the States and its legal head office in the other Contracting State, then the competent authorities of the Contracting States shall consult to determine by mutual agreement whether the legal head office of such a person is to be considered as the actual place of effective management or not.
Appears in 3 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
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 3 contracts
Samples: Convention for the Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion, 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 only of the State State, in which its place of effective management is situated.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion, Double Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual or a trust 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 3 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual individ- ual 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 3 contracts
Samples: Convention for the Elimination of Double Taxation, Convention for the Avoidance of Double Taxation, 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 it shall be deemed to be a resident only of the State in which its the 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 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 only of the State in under the laws of which its place of effective management is situatedit has been incorporated.
Appears in 3 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, 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 it shall be deemed to be a resident only of the Contracting State in which its place of effective management is situated. However, where such a person has the place of effective management of its business in one of the Contracting States and its place of incorporation in the other Contracting State, then the competent authorities of the Contracting States shall determine by mutual agreement the Contracting State of which the person shall be deemed to be a resident for the purposes of this Convention.
Appears in 3 contracts
Samples: Double Taxation Treaty, Convention for the Avoidance of Double Taxation, 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 it shall be deemed to be a resident only of the State in under the laws of which it derives its place of effective management is situatedstatus as such.
Appears in 3 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Agreement for the 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 only of the State in which its place of effective management man- agement is situated.
Appears in 3 contracts
Samples: Double Taxation Convention, Double Taxation Convention, Double Taxation Convention
Where by reason. of the provisions of paragraph 1 a person other than an individual individu- al 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 3 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, 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 it shall be deemed to be a resident only of the that Contracting 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 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 only 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 only of the State in which its place of effective management is situated. If the State in which its place of effective management is situated cannot be determined, then the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 3 contracts
Samples: Double Taxation Agreement, Agreement for Avoidance of Double Taxation of Income, Double Taxation Avoidance 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 only solely of the State in which its place of effective management is situated.
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 only of the State in which its place of effective management is situated.
Appears in 2 contracts
Samples: Double Taxation Agreement, 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 only of the State in which its place of effective management head office is situated.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance 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 only of the State in which its place of effective management registration (incorporation) is situated.
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 the Contracting StatesState, 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 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation
Where by reason. of the provisions of paragraph paragraphs 1 and 2 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident only solely of the Contracting State in which its place of effective management is situated.
Appears in 2 contracts
Samples: Income Tax Treaty, 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 only of the State in of which its place of effective management it is situateda national.
Appears in 2 contracts
Samples: Income and Capital Tax Agreement, 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 only of the State in which its place of effective management incorporation is situated.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance 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 only of the State in which its place of effective management is incorporation and place of registration are situated.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Income 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 only of the State in which its place of effective management it is situatedregistered.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion, 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 only of the State in which its place of effective management is situated. In case of doubt the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 2 contracts
Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion, 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 StatesStales, then it shall be deemed to be a resident only of the State in which its place of effective management is situated.
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 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 head office or its place of effective management is situated.
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 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 the control and management of its place of effective management business is situatedexercised.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, 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 only solely 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 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, 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 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 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident only solely of the Contracting State in which its place of effective management is situated.
Appears in 2 contracts
Samples: International Tax Agreements, 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 only solely of the State in which its place of effective management is situated. In case of doubt the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Agreement
Where by reason. of the provisions of paragraph 1 if 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.. If the State in which its place of effective management is situated cannot be determined, then the competent authorities of the Contracting States shall settle the question by mutual
Appears in 2 contracts
Samples: Double Taxation Agreement, 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 only of the State in which its place of effective management is situated, or, if that cannot be established, the competent authorities of the Contracting States shall settle the question by mutual agreement and determine the mode of application of this Agreement to such person.
Appears in 2 contracts
Samples: Income Tax Agreement, Agreement 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 a person other than an individual is a resident of both Contracting StatesState, then it shall be deemed to be a resident only of the State in which its place of effective management is situated.
Appears in 2 contracts
Samples: Income and Capital Tax Agreement, Double Taxation Avoidance 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 only of the Contracting State in which its place of effective management registered office is situated.
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 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident only solely of the Contracting State in which its place of head office (i.e. effective management management) is situated.
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 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 registered office is situated.
Appears in 2 contracts
Samples: 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 only of the Contracting State in which its place of effective management is situated. However, where such person has its place of effective management in one of the States and its legal head office in the other State, then the competent authorities of the Contracting States shall consult to determine by mutual agreement whether the legal head office of such a person has to be considered as the actual place of effective management or not.
Appears in 2 contracts
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting StatesState, then it shall be deemed to be a resident only solely of the Contracting State in which its place of effective management is situated.
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 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 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, States then it shall be deemed to be a resident only of the State in which its the place of effective management is situated. In case of doubts 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 a person other than an individual is a resident of both Contracting States, then it he shall be deemed to be a resident only of the State in which its place of effective management is situated. If the State in which its place of effective management cannot be determined, 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 1, a person other than an individual 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 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 only of if the 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 only of the State in which its place of effective management is situated.is
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 StatesSlates, then it shall be deemed to be a resident only of the State in which its place of effective management is situated. If the place of effective management cannot be determined, 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 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 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 solely of the State in which its place of effective management is situated.
Appears in 1 contract
