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 475 contracts
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 199 contracts
Samples: Double Taxation Avoidance Agreement, Agreement, 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 95 contracts
Samples: Double Taxation Agreement, Agreement, 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 84 contracts
Samples: Pengesahan Agreement, Double Taxation Agreement, 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 60 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, 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 25 contracts
Samples: Agreement, www.hacienda.gob.es, 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 solely of the State in which its place of effective management is situated.
Appears in 23 contracts
Samples: Agreement, www.hacienda.gob.es, 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.
Appears in 20 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 only of the State in which its place of effective management is situated.
Appears in 20 contracts
Samples: Double Taxation Avoidance Agreement, olsenandpartners.com, www.bazawiedzy.delegowanie.pl
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 20 contracts
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 18 contracts
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 14 contracts
Samples: Agreement, app.parlamento.pt, app.parlamento.pt
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: Double Taxation Avoidance Agreement, Agreement, 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 head office is situated.
Appears in 10 contracts
Samples: Double Taxation Agreement, www.incometaxindia.gov.in, 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 situatedmanaged and controlled.
Appears in 9 contracts
Samples: www.iras.gov.sg, Agreement, www.iras.gov.sg
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
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 9 contracts
Samples: Double Taxation Avoidance Agreement, 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 head or main office is situated.
Appears in 8 contracts
Samples: Agreement, Agreement, www.ilajapan.org
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
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
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.. PERMANENT ESTABLISHMENT
Appears in 8 contracts
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: www.mof.gov.sa, zatca.gov.sa, zatca.gov.sa
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: internationaltaxtreaty.com, www.gtakorea.org, www.gtakorea.org
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.. Permanent Establishment
Appears in 7 contracts
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, Double Taxation Agreement, www.mra.mu
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, www.incometaxindia.gov.in, 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 is situated.
Appears in 7 contracts
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, Agreement
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: Agreement, Taxation Agreement, 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 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
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, Double Taxation Agreement, 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 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: Agreement, Treaty Series 2016, 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: zatca.gov.sa, internationaltaxtreaty.com, internationaltaxtreaty.com
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, Agreement, 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 5 contracts
Samples: www.bphn.go.id, Pengesahan Agreement, Pengesahan 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 endeavour to settle the question by mutual agreement.
Appears in 5 contracts
Samples: Norway, Ministry of Finance, www.incometaxindia.gov.in
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 5 contracts
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: www.zhiyanbao.cn, Agreement of 29th, 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: Taxation Avoidance Agreement, www.nalog.ru, Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting Statesterritories, then it shall be deemed to be a resident only of the State territory in which its place of effective management is situated.
Appears in 5 contracts
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: Taxation Avoidance Agreement, Agreement, 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, www.incometaxindia.gov.in
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, Tanzania, Tanzania
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: www.nalog.ru, Taxation Avoidance Agreement, nukbunchee.com
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, Taxation Agreement, lampiran1.hasil.gov.my
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, Agreement, 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 it is situatedincorporated.
Appears in 4 contracts
Samples: Agreement, Agreement, www.tax.gov.kh
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: www.hacienda.gob.es, Agreement, internationaltaxtreaty.com
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.. Permanent Establishment
Appears in 4 contracts
Samples: www.revenue.ie, www.revenue.ie, www.revenue.ie
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: Agreement, Agreement, 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: www.nalog.ru, Notice, www.taxrus2000.com
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: ch-businessdesign.com, app.parlamento.pt, app.parlamento.pt
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: app.parlamento.pt, app.parlamento.pt, app.parlamento.pt
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
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, Taxation Avoidance Agreement, www.taxsutra.com
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: internationaltaxtreaty.com, internationaltaxtreaty.com, internationaltaxtreaty.com
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, Agreement, www.incometaxindia.gov.in
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.. Permanent Establishment
Appears in 3 contracts
Samples: www.revenue.ie, www.revenue.ie, www.revenue.ie
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: Agreement, Agreement, internationaltaxtreaty.com
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: www.parlament.gv.at, www.ris.bka.gv.at, www.parlament.gv.at
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: www.cottgroup.com, internationaltaxtreaty.com, www.dfa.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 only of the State State, in which its place of effective management is situated.
Appears in 3 contracts
Samples: Agreement, Taxation Avoidance Agreement, www.taxsutra.com
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: tayros.bg, internationaltaxtreaty.com, 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 under the laws of which it derives its place of effective management is situatedstatus as such.
Appears in 3 contracts
Samples: www.vmi.lt, internationaltaxtreaty.com, www.ujp.gov.mk
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: Agreement, internationaltaxtreaty.com, www.taxsutra.com
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: cdi.mecon.gob.ar, www.ciat.org, tpguidelines.com
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
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.. PERMANENT ESTABLISHMENT
Appears in 2 contracts
Samples: Agreement, internationaltaxtreaty.com
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, phl.hasil.gov.my
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 2 contracts
Samples: Agreement, internationaltaxtreaty.com
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
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
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 place of effective management cannot be determined, then the competent authorities shall settle the question by mutual agreement.
Appears in 2 contracts
Samples: Taxation Avoidance Agreement, www.taxsutra.com
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
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
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: internationaltaxtreaty.com, auditors.am
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 business is situatedmanaged and controlled.
Appears in 2 contracts
Samples: Taxation Avoidance Agreement, 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. Article 5
Appears in 2 contracts
Samples: internationaltaxtreaty.com, internationaltaxtreaty.com
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, www.iras.gov.sg
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, internationaltaxtreaty.com
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
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: Taxation Avoidance Agreement, internationaltaxtreaty.com
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
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: Agreement, www.taxsutra.com
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
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.. Article 5
Appears in 2 contracts
Samples: internationaltaxtreaty.com, 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 solely of the Contracting State in which its place of effective management is situated.
Appears in 2 contracts
Samples: www.nalog.ru, www.worldlii.org
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
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: Agreement, 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 is situated. However, where such person has its place of effective management in a Contracting State and the place of its legal head office in the other Contracting State, then the competent authorities of the Contracting States shall determine by mutual agreement the State of which the person shall be deemed to be a resident for the purposes of the Agreement.
Appears in 2 contracts
Samples: www.cottgroup.com, www.gov.za
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, 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 is situated.
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 States, then it shall be deemed to be a resident only of the State in which it is registered and its place of effective management is situated. If the place of registration and the place of effective management of this person is not situated in the same Contracting State, then the competent authorities of the Contracting States shall settle the question by mutual agreement and determine the mode of application of this Convention to such person.
Appears in 2 contracts
Samples: www.esteri.sm, admin.abc.sm
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: www.incometaxindia.gov.in, www.taxsutra.com
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
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 1 contract
Samples: internationaltaxtreaty.com
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 1 contract
Samples: tayros.bg
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 state in which its place of effective management is situated.
Appears in 1 contract
Samples: 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 Contracting State in which its place of effective management it is situatedincorporated, created or organized.
Appears in 1 contract
Samples: Taxation Avoidance Agreement
