Common use of Article 4 RESIDENT Clause in Contracts

Article 4 RESIDENT. For the purposes of this Agreement, the term ”resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

Appears in 1 contract

Samples: Smlouva O Zamezení Dvojímu Zdanění

Article 4 RESIDENT. For the purposes of this Agreement, the term ”resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationeffective management, place of management incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

Appears in 1 contract

Samples: Smlouva O Zamezení Dvojímu Zdanění

Article 4 RESIDENT. For the purposes of this Agreement, the term resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporationmanagement, place of management incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

Appears in 1 contract

Samples: Smlouva O Zamezení Dvojímu Zdanění

Article 4 RESIDENT. For the purposes of this Agreement, the term ”resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

Appears in 1 contract

Samples: Smlouva O Zamezení Dvojímu Zdanění

Article 4 RESIDENT. For the purposes of this Agreement, the term resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.

Appears in 1 contract

Samples: Smlouva O Zamezení Dvojímu Zdanění

Article 4 RESIDENT. For the purposes of this Agreement, the term resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income or capital gains from sources in that State or capital situated thereinState.

Appears in 1 contract

Samples: Smlouva O Zamezení Dvojímu Zdanění