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 State in which it has 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 it shall be deemed to be a resident only of the State in of which it has its place of incorporationis 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 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 in which it has its place of incorporationthat 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 of the State in which it has its place of incorporationeffective 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 company is a resident of both Contracting States, it shall be deemed to be a resident of the Contracting State in which it has 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 of the Contracting State in which its place of incorporationeffective 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 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 of the State in which it has its place of incorporationthat 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 of the Contracting State in which it has its place of incorporationeffective management is situated.
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 or organized under the laws of a Contracting State or a political subdivision thereof, it shall be deemed to be treated as a resident of the State in which it has its place of incorporationthat 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, then it shall be deemed to be a resident of the State in which it has its place of incorporationis incorporated.
Appears in 1 contract
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 under the laws of which it has its place of incorporationbeen created.
Appears in 1 contract
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 solely of the State in under the laws of which it has its place of incorporationbeen created.
Appears in 1 contract
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 of the State in which it has its place of incorporation.effective management is situated. --------------------------------------------------------------------------------
Appears in 1 contract
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 has 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 of the Contracting State in which its place of incorporationeffective management is situated.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
