Where by reason. of the provisions of paragraph 1 a company is a resident of both Contracting States, then it shall be deemed to be a resident only of the State of which it is a national.
Appears in 5 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 company is a resident of both Contracting States, then it shall be deemed to be a resident only of the State of in which it is a nationalhas its place of incorporation.
Appears in 5 contracts
Samples: Taxation Agreement, Taxation Agreement, Taxation Agreement
Where by reason. of the provisions of paragraph 1 a company is a resident of both Contracting States, then if it is created under the laws of a Contracting State or a political subdivision thereof, it shall be deemed to be a resident only of the State of which it is a nationalthat State.
Appears in 5 contracts
Samples: Convention for the Avoidance of Double Taxation, Double Taxation Treaty, Convention for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a company 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 which it effective management is a nationalsituated.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Income and Capital Tax Agreement
Where by reason. of the provisions of paragraph 1 a company is a resident of both Contracting States, then if it is created under the laws of one of the Contracting States or a political subdivision thereof, it shall be deemed to be a resident only of the State of which it is a nationalthat State.
Appears in 2 contracts
Samples: Income Tax Convention, Income Tax Convention
Where by reason. of the provisions of paragraph 1 a company 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 which it effective management is a nationalsituated.
Appears in 2 contracts
Samples: Income and Capital Tax Agreement, Double Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a company is a resident of both Contracting States, it shall be deemed to be a resident of the Contracting State in which it is incorporated or under the low of which it derives its status as a company, If the company under this criterion still 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 which it effective management is a nationalsituated.
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 company is a resident of both Contracting States, then if it is created or organized under the laws of a Contracting State or a political subdivision thereof, it shall be deemed to be treated as a resident only of the State of which it is a nationalthat State.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Tax Convention
Where by reason. of the provisions of paragraph 1 a company is a resident of both Contracting States, it shall be deemed to be a resident of the Contracting State in which it is incorporated or under the law of which it derives its status as a company. If the company under this criterion still 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 which it effective management is a nationalsituated.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a company is a resident of both Contracting States, then it shall be deemed to be a resident only of the State under the laws of which it is a nationalhas been created.
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Where by reason. of the provisions of paragraph 1 a company is a resident of both Contracting States, then it shall be deemed to be a resident only of the State of in which it is a nationalincorporated.
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Where by reason. of the provisions of paragraph 1 a company 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 which it effective management is a national.situated. --------------------------------------------------------------------------------
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Where by reason. of the provisions of paragraph 1 a company is a resident of both Contracting States, then it shall be deemed to be a resident only solely of the State under the laws of which it is a nationalhas been created.
Appears in 1 contract