RESIDENT. (1) For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 12 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 8 contracts
Sources: Agreement for the Avoidance of Double Taxation, Double Taxation Agreement, Botswana Ireland Double Taxation Avoidance Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 7 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 of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 6 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his 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 5 contracts
Sources: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement for the Avoidance of Double Taxation, Double Taxation Agreement
RESIDENT. (1) For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, legal head office, 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: 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 Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 5 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Double Taxation Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 5 contracts
Sources: Double Taxation Agreement, Agreement for the Elimination of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. (1) . For the purposes of this Agreement, 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 office, 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 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 Agreement, 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 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 4 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 of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income or capital gains from sources in that State or capital situated thereinState.
Appears in 4 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 situated 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 Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 4 contracts
Sources: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income and Capital, Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 3 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. (
1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 3 contracts
Sources: Agreement for the Elimination of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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, 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: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 3 contracts
Sources: Agreement for the Avoidance of Double Taxation, Double Taxation Agreement, Double Taxation Agreement
RESIDENT. (1) . For the purposes of this Agreement, 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 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 3 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 AgreementConvention, 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 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 Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and . The term shall also includes include that State itself, its political subdivisions and any political subdivision or local authority thereofauthorities. 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: 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 purpose of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of head office, 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 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his 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 thereinState.
Appears in 2 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation or registration, place of effective management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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, 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 the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, nature and also includes that State and 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 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, 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 Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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. 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: Double Taxation Agreement, Tax Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" means 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 effective management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State 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 thereinState.
Appears in 2 contracts
Sources: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, place of incorporation, residence, place of management or any other criterion of a similar nature. However, and also includes that State and any political subdivision or local authority thereof. This term, however, this term does not include any person who is liable to tax in that State only in respect only of income from sources in that State or capital property situated therein.
Appears in 2 contracts
Sources: Double Taxation Agreement, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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, 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 and the Prevention of Fiscal Evasion
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, nature and also includes that State and any local authority or 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 Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his that person’s domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 2 contracts
Sources: Agreement for the Elimination of Double Taxation, Agreement for the Elimination of Double Taxation
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his 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 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: Double Taxation Agreement, Double Taxation Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated 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 Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of registration, 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 situated 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 Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, nationality, head office, place of management registration, 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 thereinState.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" means 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 office, 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 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 Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion teriterion 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, Double Taxation Avoidance Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of registration, 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: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 situated 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 Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and . The term shall also includes include that State itself, its political subdivisions and any political subdivision or local authority thereofauthorities. 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: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
RESIDENT. (1) For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 authority, or statutory body thereof. This mis 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 Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, nature and also includes that State and any political subdivision 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 1 contract
Sources: Double Taxation Agreement
RESIDENT. (1) For the purposes of this Agreement, 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 incorporation, place of management, principle place of business 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 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management management, head office, 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 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of head office, 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 Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management incorporation, place of mamagement or any other criterion of a similar nature, and also includes that State and any of its political subdivision or local authority thereof. This term, however, does not include any ane 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 Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 1 contract
Sources: Double Taxation Avoidance Agreement
RESIDENT. (1) For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management management, place of registration, or any other criterion of a similar nature, and also includes that State and any political or administrative subdivision or 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 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, nature and also includes that State and any political subdivision sub-division 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
Sources: Double Taxation Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of head or main office, place of effective management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
RESIDENT. (
1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This 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 Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and State, any political subdivision or and any 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 Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, legal head office, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
RESIDENT. (1) For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his that person’s domicile, residence, legal head office, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
Sources: Double Taxation Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or any 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
Sources: Double Taxation Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision subdivisions 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: Double Taxation Agreement
RESIDENT. (1) For the purposes of this Agreement, the term "“resident of a Contracting State" means 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 administrativeterritorial 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
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 situated in that State or capital situated thereinState.
Appears in 1 contract
Sources: Double Taxation Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 situated in that State or capital situated thereinState.
Appears in 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and State, any political subdivision or subdivision, local authority or a statutory body 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: Double Taxation Avoidance Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation (registration), place of effective management or any other criterion of a similar nature, and also includes that State and any political subdivision statutory body or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
RESIDENT. (1) For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, nature and also includes that State and any political subdivision 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 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 Contracting State in respect only of income arising from sources in that State or capital situated thereinState.
Appears in 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his 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 thereofthereof . 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 Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, nature and also includes that State and any political 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 1 contract
RESIDENT. (
1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of registration, 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
Sources: Double Taxation Agreement
RESIDENT. (1) For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that the State, is liable to tax therein by reason of his domicile, residence, place of management incorporation, place of management, principle place of business or any other criterion of a similar nature, and also includes that State and any political subdivision or State, local authority thereof. This termor a statutory body thereof or, howeverin addition for Malaysia, 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 thereinits political subdivision.
Appears in 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his residence, domicile, residence, place of management 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 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, 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 Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
Sources: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, nature and also includes that State and any political subdivision or local authority or a statutory body established under an Act of Parliament or State Legislative Assembly 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
Sources: Double Taxation Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political 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 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management incorporation, place of management, or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, nature and also includes that State and any political subdivision 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
Sources: Double Taxation Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" means 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 effcetive management, place of 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, 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
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, legal head office, 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 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 1 contract
Sources: Double Taxation Agreement
RESIDENT. (1) For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision subdivisions 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 Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management effective 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 1 contract
RESIDENT. (1) For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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, 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
Sources: Tax Residency Agreement
RESIDENT. (1) . For the purposes of this Agreement, 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 office, 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 1 of this Agreement for the purposes of this Agreement, the term "resident of a Contracting State a resident" refers to that State" means any person who, its political subdivisions and local governments also comprise that State under the laws of the home, domicile, legal head office, place of management or of a similar nature any other criterion because which the taxpayer means a person. However, this term is only of income from sources in 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 apply to any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinperson.
Appears in 1 contract
Sources: Double Taxation Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
Sources: Double Taxation Agreement
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, legal head office, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "phrase “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, phrase 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: Agreement for the Avoidance of Double Taxation With Respect to Taxes on Income
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and or any political subdivision or local authority thereof, as well as a collective investment vehicle or undertaking established 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 1 contract
Sources: Agreement for the Elimination of Double Taxation With Respect to Taxes on Income
RESIDENT. (1) . For the purposes of this Agreement, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar naturenature , 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 State, or capital situated therein.
Appears in 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, nature and also includes that State and any political subdivision sub-division 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: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
RESIDENT. (1) For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
RESIDENT. (1) For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 therein.
Appears in 1 contract
RESIDENT. (1) . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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