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. 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.
Appears in 21 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, 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. But this term 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 StateState or capital situated therein.
Appears in 20 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance 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 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. But this term 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 StateState or capital situated therein.
Appears in 16 contracts
Sources: Convention for the Avoidance of Double Taxation, Income and Capital Tax Treaty, 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. 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.
Appears in 12 contracts
Sources: Double Taxation Avoidance Agreement, Double Taxation Avoidance 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 Contracting State, is liable to tax therein by reason of his domicile, residence, 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 thereof as well as a recognised pension fund of that Contracting State. But this term 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 Contracting State.
Appears in 12 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 management, place of incorporation or any other criterion of a similar nature, and also includes that State and any local authority thereof. But this term 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 StateState or capital situated therein.
Appears in 11 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. But this term 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 StateState 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 Contracting State, is liable to tax therein by reason of his domicile, residence, 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 thereof. But this term 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 Contracting State.
Appears in 10 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 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 as well as a recognised pension fund of that Contracting State. But this term 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 Contracting State.
Appears in 10 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. But this term 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 9 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 or administrative subdivision or local authority thereof. But this term 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 8 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. But this term 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 7 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 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 or administrative subdivision or local authority thereof. But this term 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 6 contracts
Sources: Convention for the Avoidance 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. 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 StateState or capital situated therein.
Appears in 6 contracts
Sources: Convention for the Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion, 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. 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.
Appears in 5 contracts
Sources: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance 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 Contracting State, is liable to tax therein by reason of his domicile, residence, 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 thereof as well as a pension fund of that Contracting State. But this term 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 Contracting State.
Appears in 5 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. But this term does not include any person who is liable to tax in , and also includes that State in respect only of income from sources in that Stateand any territorial authority or statutory body thereof.
Appears in 5 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 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 Contracting State and any political subdivision or local authority thereof. But this term 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 Contracting State.
Appears in 5 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. 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.
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 incorporation, place of 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.
Appears in 5 contracts
Sources: Double Taxation Avoidance Agreement, 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. The term also includes that State itself, its political subdivisions and local authorities. 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.
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 management head or main office, place of management, place of incorporation or any other criterion of a similar nature, and also includes that Contracting State and any political subdivision or local authority thereof. But this term 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 Contracting State.
Appears in 5 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 management, place of incorporation 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 StateState 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 or any other criterion of a similar nature, and also includes that State and any local authority thereof. But this term 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 StateState 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 incorporation (registration), place of 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.
Appears in 4 contracts
Sources: Income Tax Treaty, 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 registration, place of management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit or local authority thereof. But this term 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 StateState or property 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 or any other criterion of a similar nature, and also includes that State and any local authority thereof. But this term 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 StateState or property 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 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 Contracting State and any political subdivision or local authority thereof. But this term 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 Contracting State.
Appears in 3 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 management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political or administrative subdivision or local authority thereof. But this term 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 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 Contracting State, is liable to tax therein by reason of his domicile, residence, place of incorporation, 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 thereof as well as a recognised pension fund of that Contracting State. But this term 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 Contracting State.
Appears in 3 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 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 subdivision or local authority thereof. But this term 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 Contracting State.
Appears in 3 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 or administrative subdivision or local au- thority thereof. But this term 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 StateState 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 Contracting State, is liable to tax therein by reason of his domicile, residence, place of management head or main office, place of management, place of incorporation or any other criterion of a similar nature, and also includes that Contracting State and any political subdivision or local authority thereof, as well as a pension fund of that Contracting State. But this term 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 Contracting State.
Appears in 3 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 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. 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.
Appears in 3 contracts
Sources: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
RESIDENT. 1. For the purposes purpose 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. But this 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.
Appears in 3 contracts
Sources: Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Mauritius for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Mauritius for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Mauritius 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 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 or administrative subdivision or local au- thority thereof. But this term 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 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 management, place of registration 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 StateState 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 Any person who, under the laws of that 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. But this term 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. The government of any of the two contracting states or any of its political subdivision or local authorities.
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 Contracting State, is liable to tax therein by reason of his domicile, residence, place of head or main office, place of 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., and also includes:
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 head office or effective 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.
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 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. 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.
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 management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. 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.
Appears in 2 contracts
Sources: Double Taxation Avoidance 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. 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.
Appears in 2 contracts
Sources: Double Taxation Avoidance 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 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 Contracting State and any political or administrative subdivision or local authority thereof. But this term This term, howev- er, does not include any person who is liable to tax in that Contracting State in respect only of income from sources in that Contracting State.
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, and also includes that State and any political subdi- vision or local authority thereof. But this term This term, however, does not include in- clude any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.
Appears in 2 contracts
Sources: Model Double Taxation Convention, Model 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 management, place of incorporation or any other criterion of a similar nature. But 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 capital situated therein. For the purposes of this Convention, the Government of a Contracting State, its political subdivisions and local authorities thereof will be considered to be a resident of that Contracting State.
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 registration, place of management or any other criterion of a similar nature, and also includes that State and any political or administrative subdivision or local authority thereof. But this term 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 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. But this term 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 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 naturenature and also includes that State and any political or administrative subdivision or local au- thority thereof. But this term 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 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 Contracting State, is liable to tax therein by reason of his domicile, residence, place of management management, place of incorporation, place of head or main office or any other criterion of a similar nature, and also includes that Contracting State and any political subdivision or local authority thereof as well as a recognised pension fund of that Contracting State. But this term 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 Contracting 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 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, place of incorporation or any other criterion of a similar nature. But this term 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 StateState 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, Convention the term “resident of a Contracting State” means any person who, who under the laws of that State, State is liable to tax therein by reason of his domiciledomicile residence, residenceplace of incorporation, place of 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.
Appears in 2 contracts
Sources: Double Taxation Avoidance 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 registration, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit, political subdivision or local authority thereof. But this term 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 StateState 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 Contracting State, is liable to tax therein by reason of his domicile, residence, 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 subdivision or local authority thereof. But this term 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 Contracting 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 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. But this term This term, however, does not include any person who is liable to tax in that State state in respect only of income from sources in that Statestate.
Appears in 2 contracts
Sources: Double Taxation Avoidance 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 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. 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 StateState 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 purpose 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. But this 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 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, 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 incorporation, place of management or any other criterion of a similar nature, and also includes that State and any local authority thereof. 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 StateState or capital situated therein.
Appears in 2 contracts
Sources: Convention for the Avoidance of Double Taxation, 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 taxation therein by reason of his domicile, residence, palce of incorporation, place of 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.
Appears in 2 contracts
Sources: Convention for the Avoidance of Double Taxation, 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 incorporation, place of management or any other criterion of a similar nature, and also includes that State and any local authority thereof. But this term 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 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 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.
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, State is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature. But this term does shall not include any person who is liable to tax in that State in respect only of income from sources in that StateState 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 registration, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision, administrative-territorial unit or local authority thereof. But this term 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 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, and also includes that State and any political subdivision or local authority thereof. But this term 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 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 or any other criterion of a similar nature, and also includes that State and any local authority thereof. But this term 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 StateState or 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 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. But this term 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 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 registration, place of management or any other criterion of a similar nature, and also includes that State and any political or administrative-territorial subdivision or local authority thereof. But this term 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 StateState 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 law 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. 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.
Appears in 2 contracts
Sources: Double Taxation Avoidance 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 taxation therein by reason of his domicile, residence, place of 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 2 contracts
Sources: Agreement for Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
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 management management, place of head or main office or any other criterion of a similar nature, and also includes that Contracting State and any political or administrative subdivision or local authority thereof. But this term 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 Contracting State.
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 place of registration, place of management or any other criterion of a similar naturenature and also includes that State or local authority thereof. But this term 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 StateState 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 incorporation, place of 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.
Appears in 2 contracts
Sources: Double Taxation Avoidance 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. But 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 StateState 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 or any other criterion ▇▇▇▇▇- ▇▇▇▇ of a similar nature, and also includes that State and any political or administrative subdivision or local authority thereof. But this term 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.
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, and also includes that State and any political or administrative subdivision or local authority thereof. But this term 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 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, State is liable to tax therein by reason of his domicile, place of establishment and registration, residence, place of 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.
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, or any other criterion of a similar nature, and also includes that State and any local authority thereof. But 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 StateState 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 Contracting State, is liable to tax therein by reason of his domicile, residence, place of head or main office, place of registration, place of 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 StateState 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, State is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar naturenature and also includes that State and any local authority thereof. But this term 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 StateState ori 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 incorporation or any other criterion of a similar nature, and also includes that State and any administrative subdivision or local authority thereof. But this term 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
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, any governmental body or agency, administrative territorial subdivision or local authority thereof. But this term 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
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. But this term 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 StateState 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. 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 StateState or property 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 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. But this term 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 StateState or capital situated therein.
Appears in 1 contract
RESIDENT. 1. For the purposes of this Convention, the term “resident of a Contracting State” State means any person who, who under the laws of that State, is liable to tax therein by reason of his domicile, residenceresident, place of management head or main office, place of 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.
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. But this term does not include any person who is liable to tax in , and also includes that State in respect only of income from sources in that Stateand any political subdivision or local authority thereof.
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 of 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.
Appears in 1 contract
Sources: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
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, 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 thereof. But this term 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 Contracting State.
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. But this term 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
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, any political subdivision and any local authority thereof. But this term 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
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 local authority or administrative-territorial unit thereof. But this term 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 StateState or capital situated therein.
Appears in 1 contract
RESIDENT. 1. For the purposes of this Convention, 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. 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.
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. But this term 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
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 local authority thereof. 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.
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 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. 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.
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, place of incorporation, residence, place of management or any other criterion of a similar nature. The term shall also include the Government of that Contracting State and a local authority thereof. 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 StateState 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 incorporation or any other criterion of a similar nature, and also includes that State or local authority thereof. But this term 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
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 registration, place of effective management or any other criterion of a similar nature, and also includes that State and any administrative-territorial subdivision or local authority thereof. But this term 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 StateState 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 incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political or administrative subdivision or local authority thereof. But this term 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
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. But this term 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 StateState or capital situated therein.
Appears in 1 contract