Where by reason. of the provisions of paragraph 1 a company is a resident of both Contracting States, then its status shall be determined as follows: (a) it shall be deemed to be a resident of the State of which it is a national; (b) if it is a national of neither of the States, it shall be deemed to be a resident of the State in which its place of effective management is situated.
Appears in 8 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Agreement, 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 its status shall be determined as followsin accordance with the following rules:
(a) it shall be deemed to be a resident solely of the Contracting State in which its place of which it central management and control is a nationalsituated;
(b) if it its place of central management and control is a national of neither of the Statesnot situated in either Contracting State, it shall be deemed to be a resident solely of the Contracting State in which its place of effective management is situatedit was incorporated.
Appears in 3 contracts
Samples: International Tax Agreements, Agreement for the Avoidance of Double Taxation, International Tax Agreements
Where by reason. of the provisions of paragraph 1 a company is a resident of both Contracting States, then its status shall be determined as follows:
(a) it shall be deemed to be a resident only of the State of which it is a national;
(b) if it is a national of neither of the States, 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, Income Tax Convention, 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 its status shall be determined as follows:
(a) it shall be deemed to be a resident of the State under the laws of which it is a nationalwas created;
(b) if it is a national was created under the laws of neither of the States, it shall be deemed to be a resident of the State in which its place of effective management is situated.
Appears in 3 contracts
Samples: Income and Capital Tax Treaty, Agreement for the Avoidance of Double Taxation, 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 its status shall be determined as follows:
(a) a. it shall be deemed to be a resident of the State of which it is a national;
(b) b. if it is a national of neither of the States, it shall be deemed to be a resident of the State in which its place of effective management is situated.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, 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 its status this case shall be determined as followsin accordance with the following rules:
(a) it shall be deemed to be a resident of the Contracting State of which it is a national;
(b) if it is a national of neither of the Contracting States, it shall be deemed to be a resident the competent authorities of the State in which its place of effective management is situatedContracting States shall endeavour to settle the question by mutual agreement.
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 a company is a resident of both Contracting States, then its status shall be determined as follows:
(a) it shall be deemed to be a resident only of the State of in which it is a national;incorporated; or
(b) if it is a national of incorporated in neither of the States, 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: Income and Capital Tax Convention
Where by reason. of the provisions of paragraph 1 a company is a resident of both Contracting States, then its status shall be determined as follows:
(a) it shall be deemed to be a resident only of the State of which it is a national;
(b) if it is a national of neither of the States, 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: Income Tax Convention
Where by reason. of the provisions of paragraph 1 a company is a resident of both Contracting States, then its status shall be determined as follows:
(a) it shall be deemed to be a resident only of the State of which it is a national;; or
(b) if it is a national of neither of the States, 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: Income Tax Convention
Where by reason. of the provisions of paragraph 1 a company is a resident of both Contracting States, then its status shall be determined as followsin accordance with the following rules:
(a) it shall be deemed to be a resident of the Contracting State of which it is a national;
(b) if it is a national of neither of the Contracting States, it shall be deemed to be a resident of the Contracting State in which its place of effective management is situated.
Appears in 1 contract
Samples: Income Tax Convention
Where by reason. of the provisions of paragraph 1 a company is a resident of both Contracting States, then its status shall be determined as follows:
(a) it shall be deemed to be a resident of the State of which it is a national;
(b) if it . If the company under this criterion is a national of neither of the States, it shall be deemed to be still a resident of both States, then the State in which its place competent authorities of effective management is situatedthe Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Samples: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion
Where by reason. of the provisions of paragraph 1 a company is a resident of both Contracting States, then its status this case shall be determined as followsin accordance with the following rules:
(a) it shall be deemed to be a resident of the Contracting State of which it is a national;
(b) if it is a national of neither of the Contracting States, it shall be deemed to be a resident of the Contracting State in which its place of 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, then its status shall be determined as follows:
(a) a. it shall be deemed to be a resident only of the State of which it is a national;
(b) b. if it is a national of neither of the States, 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 company is a resident of both Contracting States, then its status this case shall be determined as followsin accordance with the following rules:
(a) 1. it shall be deemed to be a resident of the Contracting State of which it is a national;
(b) 2. if it is a national of neither of the Contracting States, it shall be deemed to be a resident of the Contracting State in which its place of 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, then its status shall be determined as follows:
(a) a. it shall be deemed to be a resident only of the State of in which it is a nationalwas incorporated or otherwise constituted;
(b) b. if it is a national of neither was not incorporated or otherwise constituted in either of the States, 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 company is a resident of both Contracting States, then its status shall be determined as follows:
(a) it shall be deemed to be a resident only of the State of which it is a national;
(b) if it is a national of neither of the States, it shall be deemed to be a resident of the State in which its place of effective management is situated.
Appears in 1 contract
