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 of the Contracting State in which its head office is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 5 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 of the Contracting State in which its head office place of effective management is situated. If the State in which its head office 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 1, a person other than an individual 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 head office (i. e. effective management) is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 4 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 of the Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated 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, 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 of the Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated , or if that cannot be determinedestablished, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 4 contracts
Samples: Double Taxation Avoidance Agreement, Taxation Avoidance 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 he shall be deemed to be a resident of the Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated place of effective management cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 4 contracts
Samples: Taxation Avoidance Agreement, 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 of the Contracting State in which its place of head office (place of effective management) is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 3 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 of the Contracting State in which its head office place of effective management is situated. If However, where such person has its place of effective management in one of the State in which States and its legal head office is situated cannot be determinedin the other Contracting State, then the competent authorities of the Contracting States shall settle the question consult to determine by mutual agreementagreement 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, 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 of the Contracting State in which its place of head office or of effective management is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
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 of the Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated cannot be determined, In case of doubt the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 3 contracts
Samples: internationaltaxtreaty.com, internationaltax.co.in, 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 of the Contracting State in which its head office place of management and control is situated. If the State in which its head office is situated cannot be determined, In case of doubts the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 3 contracts
Samples: Agreement, 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 of the Contracting State in which its head office place of effective management is situated. If However, where such a person has the State place of effective management of its business in which one of the Contracting States and its head office is situated cannot be determinedplace of incorporation in the other Contracting State, then the competent authorities of the Contracting States shall settle the question determine by mutual agreementagreement 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 a person other than an individual 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 head office is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
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 of the Contracting State in which its place of head office (place of effective management) is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 2 contracts
Samples: 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 of the Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated , or, if that cannot be determinedestablished, the competent authorities of the Contracting States shall settle the question by mutual agreementagreement and determine the mode of application of this Agreement to such person.
Appears in 2 contracts
Samples: internationaltaxtreaty.com, www.sars.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 of the Contracting State in which the control and management of its head office business is situatedexercised. If the State in which place of control and management of its head office is situated business cannot be determined, 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 of the Contracting State in which its head office place of effective management is situated. If However, where such person has its place of effective management in a Contracting State and the State in which place of its legal head office is situated cannot be determinedin the other Contracting State, then the competent authorities of the Contracting States shall settle the question determine by mutual agreementagreement 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 of the Contracting State in which its head office place of effective management is situated. If However, where such person has its place of effective management in one of the State in which States and its legal head office is situated cannot be determinedin the other State, then the competent authorities of the Contracting States shall settle the question consult to determine by mutual agreementagreement 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
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 of the Contracting State in which its legal head office is situated. If the State in which its head office is situated cannot be determined, 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 1, a person other than an individual 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 registration of its head office is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 2 contracts
Samples: www.nalog.ru, www.taxrus2000.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 of the Contracting State in which its head office is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
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, it shall be deemed to be a resident only of the Contracting State in which it is incorporated. If the person under the foregoing criteria is still a resident of both Contracting States, then it shall be deemed to be a resident only of the Contracting State in which its head office place of effective management is situated. If the State in which its head office 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 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 of the Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated cannot be determinedIn case of doubt, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, phl.hasil.gov.my
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 of the Contracting State in which its head office is situated. If the State in which its head office is situated cannot be determined, 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 1, a person other than an individual 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 head office (i. e. effective management) of its business is situated. If the State in which its head office is situated cannot be determined, 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 of the Contracting State in which its head office place of effective management is situated. If the State a place of effective management is considered as situated in which its head office is situated cannot be determinedboth Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 2 contracts
Samples: Taxation Avoidance 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 of the Contracting State in which its head or main office is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 2 contracts
Samples: Taxation Avoidance Agreement, internationaltaxtreaty.com
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 of the Contracting State in which its head office place of effective management is situated. If the State in which its head office place of effective management is situated cannot be determined, then the competent authorities of the Contracting States shall settle the question by mutual agreement.mutual
Appears in 2 contracts
Samples: 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 of the Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated cannot be determined, In case of doubts the competent authorities of the Contracting States shall settle the question by mutual agreement.. --------------------------------------------------------------------------------
Appears in 2 contracts
Samples: 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 of the Contracting State in which its head office place of management and control is situated. If the State in which its head office is situated cannot be determined, In case of doubts the competent authorities of the Contracting States State shall settle the question by mutual agreement.
Appears in 1 contract
Samples: 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 of the Contracting State in which its head registered office is situated. If the State in which its head office is situated cannot be determined, In case of doubts the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Samples: 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 of the Contracting Contracting State in which its head office is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Samples: 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 of the Contracting State in which its the place of effective management (i.e. head office office) is situated. If the State in which its head office is situated cannot be determinedShould any problem arise regarding this matter, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Samples: 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 of the Contracting State in which its head office (place of effective management) is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Samples: 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 of the Contracting State in which its head registered office is situated. If the State in which its head office is situated cannot be determined, In case of doubts the competent authorities authorites of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Samples: www.ujp.gov.mk
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 head office place of effective management is situated. If the State in which its head office 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 1 contract
Samples: 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 of the Contracting State in which its head office place of effective and central management is situated. If the State in which its head office is situated place of effective and central management cannot be determined, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement.
Appears in 1 contract
Samples: www.revenue.ie
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 of the Contracting State in which its legal head office is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Samples: 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 of the Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated 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
Samples: Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, it shall be deemed to be a resident of the Contracting State in which it is incorporated. If the person under the foregoing criterion is still a resident of both Contracting States, then it shall be deemed to be a resident of the Contracting State in which its head office place of effective management is situated. If the State in which its head office 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 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 of the Contracting State in which its the place of head office (i.e, place of effective management) is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Samples: 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 of the Contracting State in which its head office place of effective management is situated. If However, where such person has its place of effective management in one of the State in which States and its legal head office is situated cannot be determinedin the other State, then the competent authorities of the Contracting States State shall settle the question consult to determine by mutual agreementagreement whether the legal head office of such a person has to be considered as the actual place of effective management or not.
Appears in 1 contract
Samples: Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting State, it shall be deemed to be a resident of the Contracting State in which it is incorporated. If the person under the foregoing criterion is still a resident of both Contracting States, then it shall be deemed to be a resident of the Contracting State in which its head office place of effective management is situated. If the State in which its head office 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 1 contract
Samples: 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 of the Contracting State in which its head office place of effective and central management is situated. If the State in which its head office is situated place of effective and central management cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Samples: www.gov.il
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 of the Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated cannot be determined, In case of doubt the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Samples: 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 of the Contracting State in which its place of head office is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Samples: 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 of the Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated cannot be determinedIn case of doubt, the competent authorities of the Contracting States shall settle resolve the question by mutual agreement.
Appears in 1 contract
Samples: 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 of the Contracting State in which its head office is office(place of effective management)is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Samples: Agreement