With reference to Article 4. The term "
With reference to Article 4. It is understood that a collective investment vehicle is a resident of a Contracting State if under the domestic laws of that State it is liable to tax therein by reason of its domicile, residence, place of management or any other criterion of a similar nature. A collective investment vehicle is also considered liable to tax if it is subject to the tax laws of that Contracting State but is exempt from tax only if it meets all the requirements for exemption specified in the tax laws of that Contracting State.
With reference to Article 4. All the activities concerning the purchase, sale and transport of raw materials and derivative products, energy, fuels, capital goods, as well as any other operation connected to them or in any way connected to entrepreneurial initiatives provided for in this Agreement, will also enjoy, in the territory of each Contracting Party, for a treatment no less favorable than that accorded to similar activities and initiatives of resident citizens or investors from Third Countries.
With reference to Article 4. It is agreed that government institutions of Kuwait within the meaning of sub- paragraph c) of paragraph 2 of this Article are the following corporate entities created under public law which are wholly owned and controlled by the State of Kuwait: - the Central Bank of Kuwait, - public corporations, - authorities, - government agencies, - foundations, - development funds. Subject to the provisions of sub-paragraph c) of paragraph 2 of this Article further institutions can be recognized as government institutions.
With reference to Article 4. For the purposes of paragraph 1, the term “resident of a Contracting State” shall also include a statutory body of a Contracting State. In the case of the Sultanate of Oman, it shall include the State General Reserve Fund.
With reference to Article 4. The term "resident" also includes a Contracting State or a political subdivision or local authority thereof.
With reference to Article 4. 1. A collective investment vehicle which is established in a Contracting Party and that is treated as a body corporate for tax purposes in that Contracting Party shall be considered as a resident of the Contracting Party in which it is established and as the beneficial owner of the income it receives.
With reference to Article 4. (i) A collective investment vehicle which is established in a Contracting State and that is treated as a body corporate for tax purposes in this Contracting State shall be considered as a resident of the Contracting State in which it is established and as the beneficial owner of the income it receives.
(ii) A collective investment vehicle which is established in a Contracting State and that is not treated as a body corporate for tax purposes in this Contracting State shall be considered as an individual who is resident of the Contracting State in which it is established and as the beneficial owner of the income it receives.
With reference to Article 4. For the purpose of paragraph 3 of Article 4, "place of effective management" means the place where substantial business activities are carried on and the management and control of the business is exercised.
With reference to Article 4. For the purposes of this Agreement, a person who applies for a certificate of residence will be issued with such a certificate stating the residence status of that person in a Contracting State. This certificate will, in accordance with the laws of each State, clearly manifest the person’s condition of residence in the Contracting State for the purposes of the Agreement.
