Common use of Residence Clause in Contracts

Residence. 1. For the purposes of this Convention, 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, citizenship, place of management, place of incorporation, or any other criterion of a similar nature.

Appears in 4 contracts

Samples: www.unclefed.com, www.irs.gov, www.swissbanking.ch

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Residence. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws who is resident in a Contracting State for tax purposes of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, or any other criterion of a similar nature.

Appears in 4 contracts

Samples: Agreement, Double Taxation Avoidance Agreement, Agreement

Residence. 1. For the purposes of this Convention, 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, citizenship, place of management, place of incorporation, or any other criterion of a similar nature., provided, however, that

Appears in 4 contracts

Samples: www.irs.gov, www.unclefed.com, qi-toolkit.swissbanking.org

Residence. 1. For the purposes of this Convention, 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, citizenship, place of managementCitizenship, place of incorporation, or any other criterion of a similar nature. However, this term does not include any person who is liable to tax in that State in respect only of income from sources in that State or property situated therein.

Appears in 3 contracts

Samples: tax.gov.ua, www.irs.gov, www.swissbanking.ch

Residence. (1. ) For the purposes of this ConventionAgreement, 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, citizenship, place of management, place of incorporation, incorporation or any other criterion of a similar nature.

Appears in 3 contracts

Samples: Agreement, Agreement, Agreement

Residence. 1. For the purposes of this Convention, 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, citizenship, place of management, place of incorporation, or any other criterion of a similar nature. However, this term does not include any person that is liable to tax in that State in respect only of income from sources in that State.

Appears in 3 contracts

Samples: www.swissbanking.ch, www.irs.gov, www.unclefed.com

Residence. 1. For the purposes of this Conventionconvention, 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, citizenship, place of management, place of incorporation, or any other criterion of a similar nature., provided, however, that

Appears in 3 contracts

Samples: www.unclefed.com, www.irs.gov, qi-toolkit.swissbanking.org

Residence. (1. ) For the purposes of this Convention, 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, citizenship, place of management, place of incorporation, incorporation or any other criterion of a similar nature; the term does not include any person who is liable to tax in that Contracting State only if he derives income or capital gains from sources therein.

Appears in 2 contracts

Samples: www.emta.ee, www.rahandusministeerium.ee

Residence. (1. ) For the purposes purpose of this ConventionAgreement, the term "resident of a Contracting State" means any person who, under the laws law of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, incorporation or any other criterion of a similar naturenature and also includes that State and any political subdivision or local authority thereof.

Appears in 2 contracts

Samples: Oman Double Taxation Agreement, Oman Double Taxation Agreement

Residence. (1. ) For the purposes of this Conventionagreement, the term "resident of a Contracting State" contracting state’ means any person who, under the laws of that Statestate, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, incorporation or any other criterion of a similar nature, and also includes that state and any political subdivision, local authority or statutory body thereof.

Appears in 1 contract

Samples: Taxation Agreement

Residence. 1. For the purposes of this ConventionAgreement, 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, citizenship, place of management, place of incorporation, effective management or any other criterion of a similar nature. However, the term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

Appears in 1 contract

Samples: internationaltaxtreaty.com

Residence. 1. For the purposes of this ConventionAgreement, 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, citizenship, place of management, place of incorporation, incorporation or any other criterion of a similar nature. The term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

Appears in 1 contract

Samples: www.nalog.ru

Residence. 1. a) For the purposes of this Convention, 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, citizenship, place of management, place of 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 of profits attributable to a permanent establishment in that State.

Appears in 1 contract

Samples: internationaltaxtreaty.com

Residence. 1. For the purposes of this Convention, 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, citizenship, place of management, place of incorporation, incorporation (registration) or any other criterion of a similar nature, and also includes that State, any political subdivision and any statutory body 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.

Appears in 1 contract

Samples: www.hacienda.gob.es

Residence. 1. For the purposes of this ConventionAgreement, 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, citizenship, place of management, place of incorporation, management or any other criterion of a similar nature.

Appears in 1 contract

Samples: www.incometaxindia.gov.in

Residence. 1. For the purposes of this ConventionAgreement, 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, citizenship, place of management, place of incorporation, management or any other criterion of a similar nature.

Appears in 1 contract

Samples: Double Taxation Agreement

Residence. 1. For ) Except as provided in this paragraph, for the purposes of this Convention, 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, citizenship, place of management, place of incorporation, or any other criterion of a similar nature, except that a United States citizen or alien lawfully admitted for permanent residence (a “green card” holder) shall be considered to be a resident of the United States only if such person has a substantial presence, permanent home or habitual abode in the United States.

Appears in 1 contract

Samples: qi-toolkit.swissbanking.org

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Residence. 1. For the purposes of this ConventionAgreement, 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, citizenship, place of management, place of incorporation, incorporation or any other criterion of a similar nature, and also includes that State and any statutory body 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: Agreement

Residence. 1. For the purposes of this Convention, 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, citizenship, place of management, place of incorporation, incorporation or any other criterion of a similar nature; the term does not include any person who is liable to tax in that Contracting State in respect only of income or capital gains from sources situated therein.

Appears in 1 contract

Samples: www.vmi.lt

Residence. 1. For the purposes of this ConventionAgreement, 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, citizenship, place of management, place of incorporation, incorporation (registration) or any other criterion of a similar nature, and also includes that State, and any political subdivision, statutory body 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.

Appears in 1 contract

Samples: Agreement

Residence. (1. ) For the purposes of this ConventionAgreement, 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, citizenship, place of management, place of incorporation, 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 or capital gains from sources in that State.

Appears in 1 contract

Samples: Agreement

Residence. 1. For the purposes of this ConventionAgreement, 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, citizenship, place of management, place of incorporation, incorporation (registration) or any other criterion of a similar nature, and also includes that State and any political subdivision, statutory body 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: Agreement

Residence. (1. ) For the purposes purpose of this Convention, 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, citizenship, place of management, place of incorporation, management or any other criterion of a similar nature. But this term 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: assets.publishing.service.gov.uk

Residence. 1. For the purposes of this ConventionAgreement, the term "resident of a Contracting State" means any person who, under who is a resident of that State in accordance with the taxation laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, or any other criterion of a similar nature.

Appears in 1 contract

Samples: Agreement

Residence. 1. For the purposes of this ConventionAgreement, 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, citizenship, place of management, place of incorporation, management or any other criterion of a similar nature. However, the term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

Appears in 1 contract

Samples: internationaltaxtreaty.com

Residence. (1. ) For the purposes of this ConventionAgreement, 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, citizenshipregistered office, place of management, place of incorporation, management or any other criterion of a similar nature.

Appears in 1 contract

Samples: Turkey Double Taxation Agreement

Residence. 1. For the purposes of this ConventionAgreement, 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, citizenship, place of management, place of incorporation, incorporation (registration) or any other criterion of a similar nature, and also includes that State and any statutory body 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.

Appears in 1 contract

Samples: Agreement

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