Ad Article. 4 a) It is understood that the term "resident of a Contracting State" also includes: i) any statutory body of a Contracting State, and ii) a pension fund that is recognised and controlled according to the domestic law, including regulations, of a Contracting State. b) An individual living aboard a ship without any real domicile in either Contracting State shall be deemed to be a resident of the Contracting State in which the ship has its home harbour.
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Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation