RESIDENT. 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, 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 21 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, 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 18 contracts
Sources: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, 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, 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 13 contracts
Sources: Convention for the Avoidance of Double Taxation, Double Taxation Agreement, Convention for the Avoidance of Double Taxation
RESIDENT. 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, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or subdivision, local authority or statutory body 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 11 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
RESIDENT. (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, place of management 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 capital situated therein.
Appears in 10 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, place of management 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 or capital gains from sources in that State or capital situated thereinState.
Appears in 9 contracts
Sources: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation
RESIDENT. 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, 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, 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 thereinState.
Appears in 7 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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 residence, domicile, residencecitizenship, place of management management, place of incorporation, or any other criterion of a similar nature.
2. a) However, and also includes that State and any political subdivision or local authority thereof. This term, however, the term "resident of a Contracting State" 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.State;
Appears in 6 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, place of management 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, 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 6 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, 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 6 contracts
Sources: Agreement for the Elimination of Double Taxation, Agreement for the Elimination of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. 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, place of management 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 capital situated thereinState.
Appears in 5 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, place of management or any other criterion of a similar nature, and also includes that State and any political administrative-territorial 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 5 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 1. For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws of that Contracting State, is liable to tax therein by reason of his domicile, residence, place of head or main office, place of incorporation, place of management or any other criterion of a similar nature, and also includes that Contracting State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that Contracting State in respect only of income from sources in that State or capital situated thereinContracting State.
Appears in 5 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation
RESIDENT. 1. For the purposes of this ConventionAgreement, the term “resident of a Contracting State” means any person who, under the laws of that Contracting State, is liable to tax therein by reason of his domicile, residence, place of management or head office, 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 5 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
RESIDENT. 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, 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 5 contracts
Sources: Double Taxation Avoidance Agreement, Income Tax Agreement, Agreement for the Avoidance of Double Taxation
RESIDENT. (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, place of management management, place of registration 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 5 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. (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, place of management 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 or capital from sources in that State or capital situated thereinState.
Appears in 5 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Agreement
RESIDENT. 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 their domicile, residence, 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 5 contracts
Sources: Double Tax Agreement, Agreement for the Elimination of Double Taxation, Agreement for the Elimination of Double Taxation
RESIDENT. 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, place of incorporation, place of effective management, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or subdivision, local authority or statutory body 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 4 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion, Agreement for the Avoidance of Double Taxation
RESIDENT. 1. For the purposes of this Convention, the term “"resident of a Contracting State” means " means:
(a) any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and also includes ;
(b) the Government of that State and any or a political subdivision or local authority thereofthereof or any agency or instrumentality of any such government, subdivision or authority. This term, however, 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 thereinState.
Appears in 4 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT.
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 that person’s 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 thereofthereof as well as a recognised pension fund of that State. 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.State.
Appears in 4 contracts
Sources: African Model Agreement for the Elimination of Double Taxation, African Model Agreement for the Elimination of Double Taxation With Respect to Taxes on Income and the Prevention of Tax Avoidance and Evasion, African Model Agreement for the Elimination of Double Taxation
RESIDENT. 1. For the purposes of this Convention, 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, place of management 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, But this term does not include any person who is liable to tax in that State in respect only of income from sources situated in that State or capital situated thereinState.
Appears in 4 contracts
Sources: Income Tax Convention, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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 that person’s domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or subdivision, local authority or statutory body 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 4 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. 1. For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws of that State, State is liable to tax therein in that State 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 administrative 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 4 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, place of management registration, place of incorporation, place of management, or any other criterion of a similar nature, and also includes that State and or 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 4 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
RESIDENT. 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, place of management registration, place of management, or any other criterion of a similar nature, nature and also includes that State and any political or administrative 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 4 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. 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 that person's domicile, residence, 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 4 contracts
Sources: Income Tax Agreement, Income Tax Agreement, Income Tax Agreement
RESIDENT. 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 that person’s domicile, residence, 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 4 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, place of management 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 capital situated thereinState.
Appears in 4 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, 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 4 contracts
Sources: Agreement for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, 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 4 contracts
Sources: Convention for the Avoidance of Double Taxation, Double Taxation Agreement, Convention for the Avoidance of Double Taxation
RESIDENT. 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, place of management 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 or capital gains from sources in that State or capital situated thereinState.
Appears in 3 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
RESIDENT. 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, place of management or any other criterion of a similar nature, 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 3 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Double Tax Treaty
RESIDENT. 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, place of management 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 capital situated thereinState.
Appears in 3 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, 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 3 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, 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, 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 3 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, 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, 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 3 contracts
Sources: Income and Capital Tax Convention, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, place of management management, place of incorporation or any other criterion of a similar nature, 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 3 contracts
Sources: Agreement for the Avoidance of Double Taxation, Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
RESIDENT. 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, place of registration, 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 3 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
RESIDENT. 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, 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 3 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion, Agreement for the Avoidance of Double Taxation
RESIDENT. 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, 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, howeverhow- ever, 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 3 contracts
Sources: Double Taxation Convention, Double Taxation Convention, Double Taxation Convention
RESIDENT. (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, place of management management, place of incorporation or any other criterion of a similar nature, and . The term also includes the Government of that State itself, its political subdivisions and any political subdivision or local authority thereofauthorities. This term, however, 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 3 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
RESIDENT. 1. For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws law of that State, State is liable to tax therein taxes in that State by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political administrative subdivision or local authority authorities 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 3 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 1. For the purposes of this ConventionAgreement, the term “resident of a Contracting State” means any person who, under the laws of that Contracting State, is liable to tax therein by reason of his domicile, residence, place of management management, place of head or main office or any other criterion of a similar nature, and also includes that State Contracting State, any federal state (Land) thereof and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that Contracting State in respect only of income from sources in that State or capital situated thereinContracting State.
Appears in 3 contracts
Sources: Agreement for the Elimination of Double Taxation, Agreement for the Elimination of Double Taxation, Agreement for the Elimination of Double Taxation
RESIDENT. (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, place of management head or main office, place of management, place of registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, 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 thereinState.
Appears in 2 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement
RESIDENT. 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, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereofthereof as well as a recognised pension fund of that State. 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 2 contracts
Sources: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation
RESIDENT. 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 that person’s domicile, residence, legal head office (registered office), place of management or any other criterion of a similar nature, 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 2 contracts
RESIDENT. 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, place of incorporation, place of management or any other criterion criteria of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, 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 thereinState.
Appears in 2 contracts
Sources: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
RESIDENT. 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, 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 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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 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 capital situated thereintherein or of profits attributable to a permanent establishment in that State.
Appears in 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Double Taxation Convention
RESIDENT. (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, 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, 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 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Income and Capital Tax Convention
RESIDENT. 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, place of incorporation (or registration), place of management or any other criterion of a similar nature, and . The term 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 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. 1. For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws law of that State, State is liable to tax therein taxes in that State 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 States and any political administrative subdivision or local authority authorities 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 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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 that person’s domicile, residence, place of management or any other criterion of a similar nature, and also and, where applicable, 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 2 contracts
Sources: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
RESIDENT. 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, place of incorporation, place of management or any other criterion of a similar nature, and also includes include that State and any political administrative 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 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, place of head office, place of registration, 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 2 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
RESIDENT. 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 as a resident of that State or is liable to tax by reason of his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereofthereof as well as a recognised pension fund of that State. 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 2 contracts
Sources: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation
RESIDENT. 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, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision administrative-territorial subdivisions or local authority thereofauthority. This term, however, 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 property situated therein.
Appears in 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, place of incorporation, place of management or any other criterion of a similar nature, 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 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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 that person’s domicile, residence, place of management 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 capital situated therein.
Appears in 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, place of management management, place of incorporation, place of registered office or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof, as well as a recognised pension fund of that State. 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 therein.
Appears in 2 contracts
Sources: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation
RESIDENT. 1. For the purposes of this Convention, the term “" resident of a Contracting State” State " means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, 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 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, place of management management, place of registration, place of incorporation or any other criterion of a similar nature, and also includes that State and any political or administrative territorial 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 therein.
Appears in 2 contracts
Sources: Tax Agreement, Double Taxation Agreement
RESIDENT. 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, place of management 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 or capital gains from sources in that State or capital situated therein.
Appears in 2 contracts
Sources: Double Taxation Convention, Income and Capital Tax Convention
RESIDENT. 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, 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 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. 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 that person’s domicile, residence, place of management 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 capital situated therein.
Appears in 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, 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 2 contracts
Sources: Income Tax Convention, Convention for the Avoidance of Double Taxation
RESIDENT. 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, place of management management, place of registration 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 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. 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 that person’s domicile, residence, 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 2 contracts
Sources: Double Taxation Agreement, Convention for the Avoidance of Double Taxation
RESIDENT. 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, place of management or any other criterion of a similar nature, and also includes that State and any governmental body or agency, 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 2 contracts
Sources: Convention for the Elimination of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, 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 therein.
Appears in 2 contracts
Sources: Agreement for the Elimination of Double Taxation, Income and Capital Tax Agreement
RESIDENT. (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, place of management or any other criterion of a similar nature, and also includes that State State, a Land 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 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Income and Capital Tax Agreement
RESIDENT. - 1. ) For the purposes of this Convention, 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, 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 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, place of management management, place of registration or any other criterion of a similar nature, and also includes that State and any State, 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 situated in that State or capital situated thereinState.
Appears in 2 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
RESIDENT. 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, place of management or any other criterion of a similar nature, nature and also includes that State and any political or administrative 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 2 contracts
Sources: Income and Capital Tax Convention, Income and Capital Tax Convention
RESIDENT. 1. For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws of that Contracting State, is liable to tax therein by reason of his domicile, residence, place of incorporation or organisation, place of head or main office, place of management or any other criterion of a similar nature, and also includes that Contracting State and any political subdivision or local authority thereofthereof as well as a recognised pension fund of that Contracting State. This term, however, does not include any person who is liable to tax in that Contracting State in respect only of income from sources in that State or capital situated thereinContracting State.
Appears in 2 contracts
Sources: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation
RESIDENT. 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, place of management registration, place of management, or any other criterion of a similar nature, and . The term “resident of a Contracting State” also includes that State or its local authorities or a legal person organized under the laws of a Contracting State and any political subdivision or local authority thereofthat is generally exempt from tax in that State. 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 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. 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, place of management management, place of incorporation or any other criterion of a similar nature, and also includes that State and any governmental body or agency, 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 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. (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, place of incorporation or establishment, 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 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, place of management or any other criterion of a similar nature, and also includes that State State, a “Land” and any political subdivision or local authority thereofof that State or “Land”. 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 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. 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 as a resident of his domicile, residence, place of management or any other criterion of a similar naturethat State, and also includes the Government of 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 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, place of incorporation, place of management or any other criterion of a similar nature, nature and also includes that State and any State, its political subdivision or and its local authority thereofauthority. 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 2 contracts
Sources: Double Taxation Agreement, Double Taxation Avoidance Agreement
RESIDENT. 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, place of management 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 capital situated therein.
Appears in 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
RESIDENT. 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, place of management or any other criterion of a similar nature, and also includes that State and State, any political subdivision or local authority thereof. This term, 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
RESIDENT. 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, place of management management, place of registration 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
RESIDENT. 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, legal head office (place of management incorporation), place of man- agement 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
RESIDENT. 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, place of management 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 capital situated therein. .
Appears in 1 contract
RESIDENT. 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 that person’s domicile, residence, 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
RESIDENT. 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, 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, 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
Sources: Double Taxation Avoidance Agreement
RESIDENT. 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, 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, But this term does not include any person who is liable to tax in that State in respect only of income obtained from sources situated in that State or for capital situated he may possess therein.
Appears in 1 contract
Sources: Income and Capital Tax Convention
RESIDENT. 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, 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
RESIDENT. 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, 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 termterm does not, however, does not include any person who is liable to tax taxation in that State in respect only of income from sources in that State or capital situated therein.
Appears in 1 contract
Sources: Income and Capital Tax Convention
RESIDENT. 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, place of management registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, 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 property situated therein.
Appears in 1 contract
Sources: Double Tax Treaty
RESIDENT. 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, place of incorporation, place of management or any other criterion of a similar nature, 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
RESIDENT. 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, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision subdivision, administrative-territorial unit 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
Sources: Income and Capital Tax Convention
RESIDENT. 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 nationality, domicile, residence, place of management 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, 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
RESIDENT. 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, place of management management, place of registration or any other criterion of a similar nature, and also includes that State and any political subdivision or subdivision, local authority thereofor administrative - territorial unit thereof as well as a recognised pension fund of that State. 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
RESIDENT. (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, place of management or any other criterion of a similar nature, and also includes that State State, a Land and any political subdivision administrative-territorial unit 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
Sources: Income and Capital Tax Convention
RESIDENT. 1. For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws of that State, 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, 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 thereinState.
Appears in 1 contract
Sources: Income Tax Convention
RESIDENT. 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 that person’s domicile, residence, 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