Common use of RESIDENT Clause in Contracts

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, 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.

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, place of incorporation 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, or of capital situated therein.

RESIDENT. 1. For 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, 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.

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, place of incorporation or any other criterion of a similar nature. But this The term also includes the Government of that State itself, its political subdivisions and local authorities. 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.

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, place of incorporation 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 or capital situated therein.

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, place of incorporation management or any other criterion of a similar nature. The term also includes the Government of that Contracting State and a local authority thereof. 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 StateState or capital situated therein.

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, place of incorporation or any other criterion of a similar nature. But this term does not include any person individual who is liable to tax ordinarily resident, or has his or her domicile in that State in respect only and any company or other body of income from sources persons which has its place of effective management or incorporation in that State.

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 managementregistration, place of incorporation 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.

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 Lax therein by reason of his domicile, residence, place of managementincorporation, place of incorporation management or any other criterion of or 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.

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, place of incorporation or any other criterion of a similar nature. The term shall also include 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 StateState or capital situated therein.

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 in that State by reason of his domicile, residence, place of managementincorporation, place of incorporation management or any other criterion of a similar nature, and also includes that State and any local authorities 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.

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 this domicile, residence, place of management, place of incorporation management or any other criterion of a similar nature. But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

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, 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.

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, place of incorporation management or any other criterion of a similar nature. But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

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, 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 situated in that StateState or capital situated therein.

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, place of incorporation or any other criterion of a similar naturenature 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.

RESIDENT. 1. For the purposes of this Convention, the term "“resident of a Contracting State" means ” refers to any person who, under the laws of that State, is liable to tax therein by reason of his or her domicile, residence, place of management, place of incorporation headquarters or any other criterion of a similar naturenature and also includes that State itself and any political subdivisions or local entities. But this term This term, however, does not include any person persons who is are liable to tax in that State in respect only of income from sources in that Statesaid State situated therein, or from capital located in the same.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason as a resident of his domicilethat State, residenceand also includes the Government of that State and any political subdivision or local authority thereof. This term, place of managementhowever, 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.

RESIDENT. 1. 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 managementmanage- ment, place of incorporation or any other criterion of a similar nature. But 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.

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, place of registration or incorporation, residence, place of management, place of incorporation management or any other criterion of a similar nature, and also includes that Contracting State and any administrative subdivision, central 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.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein as a resident of that State or is liable to tax by reason of his domicile, residence, place of management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof as well as a recognised pension fund of that State. 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.

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, place of incorporation 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.

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, place of incorporation 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.

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, place of incorporation or any other criterion of a similar nature. The term shall also include the Government of that Contracting State or 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.

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 income tax therein by reason of his domicile, residence, place of managementincorporation, place of incorporation 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 situated therein.

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, place of incorporation management or any other criterion of a similar nature, and also includes that State and any administrative-territorial subdivisions or local authority. 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.

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 managementincorporation, place of incorporation 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.

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, 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.

RESIDENT. 1. For the purposes of this ConventionAgreement, the term "resident of a Contracting State" means any person who, who under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of effective management, place of incorporation 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 Statestate.

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 taxation therein by reason of his domicile, residence, place of managementregistration, place of incorporation 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 StateState or capital situated therein.

RESIDENT. 1. For the The purposes of this Convention, the term "resident of a Contracting State" means any person whowho , under the laws law of that StateState , is liable to tax therein by reason of his domicile, residence, place of management, place of incorporation 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 State.

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 managementincorporation, place of incorporation management or place of registration or any other criterion of a similar nature, and also includes that Contracting State and any political subdivision or local authority or statutory body 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.

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 the person’s domicile, residence, place of management, place of incorporation management or any other criterion of a similar naturenature and also includes that State or a political subdivision or local authority thereof or any agency or instrumentality of any such State, subdivision or authority. 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.

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, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority of a “Land” or a 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 if he derives income or capital gains from sources in that Statetherein or capital situated therein.

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 managementmanagement or 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. 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.

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, place of incorporation or any other criterion of a similar naturenature 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 of capital situated therein.

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 there- in by reason of his domicile, residence, place of managementincorporation, place of incorporation man- agement 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.

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 this domicile, residence, place of management, place of incorporation management or any other criterion of a similar nature. But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

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, place of incorporation management or any other criterion of a similar nature. But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

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 State has undergone in that State taxation by reason of his domicile, residence, place of management, place of incorporation or any other criterion of a similar naturecriteria. But this This term 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 in that State. For purposes of this contract shall be Government Contracting State, its political subdivisions and local authorities are considered to be a resident of that Contracting State.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws law of that State, State is liable to tax therein taxes in that State by reason of his domicile, residence, place of management, place of incorporation management or any other criterion of a similar nature. But this term , and also includes that State and any administrative subdivision or local authorities thereof; This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.

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, place of incorporation 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.

RESIDENT. 1. For the purposes of this Convention, the term "“resident of a Contracting State" ” means any person who, under the laws of that State, is liable to tax therein by reason of his that person’s domicile, residence, place of management, place of incorporation management or any other criterion of a similar nature. But this term does not include any person who is liable to tax in , and also includes that State in respect only of income from sources in that Stateand any political subdivision or local authority thereof.

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, place of incorporation 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.

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, place of incorporation registration or any other criterion of a similar nature. But , 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.

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 the person's domicile, residence, place of management, place of incorporation or any other criterion of a similar naturenature and also includes that State and any political subdivision or local authority thereof or any agency or instrumentality of any such subdivision or authority. 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.

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 managementregistration, place of incorporation 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 StateState or capital situated therein.

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, place of incorporation 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.

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, place of incorporation management or any other criterion of a similar naturenaturs. 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.

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, place of incorporation 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.

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, place of incorporation or any other criterion of a similar nature. The term shall also include the Government of that Contracting State or a local authority thereof. But this term does not include any person who is liable to tax in that Contracting State in respect only of income from sources in that StateState or capital situated therein.

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, place of incorporation management or any other criterion of a similar naturenature and also includes that State and any political subdivision or local authority or administrative - territorial unit. 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.

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, 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.

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 income tax therein by reason of his domicile, residence, place of 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 StateState situated therein.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person whowhose income or capital, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management, place of incorporation management or any other criterion of a similar nature. But this term does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.

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, place of incorporation management or any other criterion of a similar nature. But this term does not include any person who is liable to tax in , and also includes that State in respect only of income from sources in that Stateand any political subdivison or local authority thereof.

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 managementincorporation of a legal person by registration, place of incorporation 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 StateState or capital situated therein.

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, 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.

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 managementincorporation, place of incorporation management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof as well as a recognized pension fund of that State. 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.

RESIDENT. 1. For the The purposes of this Convention, the term "resident of a Contracting State" means any person whowho , under the laws law of that StateState , is liable to tax therein by reason of his domicile, residence, place of managementregistered office , place of incorporation management or any other criterion of a similar nature. But , this term does not include any person who includes the state itself and its political subdivisions or local authorities. The term "resident of a Contracting State " includes partnerships and other groups of persons whose place of management in that State and each member is personally liable to tax in that State in respect only for its share of income from sources in the profits under the domestic laws of that State.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his nationality, domicile, residence, place of management, place of incorporation 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.

RESIDENT. 1. For the purposes of this Convention, the term "“resident of a Contracting State" means ” refers to any person who, under the laws of that State, is liable to tax therein by reason of his or her domicile, residence, place of managementheadquarters, place of incorporation establishment or any other criterion of a substantially similar naturenature and also includes that State itself and any political subdivisions or local entities. 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 Statesaid State situated therein, or from capital located in the same.

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, place of incorporation incorporation, or any other criterion of a similar naturenature and also includes that State and any political subdivision or local authority thereof. 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.

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 managementincorporation, place of incorporation management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof as well as a recognised pension fund. 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.

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, place of incorporation or any other criterion of a similar nature, and also includes that State, a Land 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.

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 managementincorporation, place of incorporation 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.

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, place of incorporation 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, or capital situated therein.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his that person's domicile, residence, place of management, 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.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, who under the laws law of that State, is liable to tax therein by reason of his domicile, residence, place of management, place of incorporation management or any other criterion of a similar naturecircumstance. 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.. 2nd Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status as follows:

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, place of incorporation management or any other criterion of a similar nature, and also includes that State or 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.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his that person’s domicile, residence, place of management, place of incorporation 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.

RESIDENT. 1. For the purposes of this Convention, the term "resident of a Contracting State" means any individual who is ordinarily resident in that State and any other person who, which has its place of management in that State or any other person who under the tax laws of that State, State is liable to tax therein by reason a resident of his domicile, residence, place of 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.

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, 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 StateState or capital situated therein.

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 managementregistration, place of incorporation management or any other criterion of a similar nature, and also includes that Contracting State and any political subdivision, central 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.

RESIDENT. 1. For the purposes of this the present Convention, the term "expression “resident of a Contracting State" means ” designates any person whothat, under by virtue of the laws legislation of that this State, is liable subject to tax therein taxation in this State by reason of his this person's domicile, residence, place of management, place of incorporation management or any other criterion criteria of a similar an analogous nature. But However, this term expression does not include any person who is liable those persons that are subject to tax in that this State in respect only of for income from sources situated in that Statethis State or for capital situated there.

RESIDENT. 1. For the purposes of this Convention, the term "“resident of a Contracting State" means ” refers to any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management, place of incorporation establishment or any other criterion of a similar naturenature and also includes the State per se 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 Statesaid State situated therein or from capital located in the same.

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, 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.

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, place of incorporation 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.

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 managementregistration, place of incorporation 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 State.

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 managementincorporation, place of incorporation management or any other criterion of a similar nature. .But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State, or capital situated therein.

RESIDENT. 1. a) For the purposes of this Convention, the term "resident of a Contracting State" means any person who, who under the laws law of that State, is liable to tax therein by reason of his domicile, residence, place of management, place of incorporation or other similar circumstances. And also includes that State and any other criterion of a similar naturepolitical subdivision or local authority. 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 or only of income as is attributable to a permanent establishment in that State.

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 managementincorporation, place of incorporation management or any other criterion of a similar nature. But this term does not include any person who is liable to tax in , and also includes that State in respect only of income from sources in that Stateand any political subdivision or local authority thereof.

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 taxation therein by reason of his domicile, residence, place of management, place of incorporation or any other criterion of a similar nature. But this This term does not include also includes the Government of the Contracting State or a political subdivision or local authority thereof or any person who is liable to tax in that State in respect only agency or instrumentality of income from sources in that Stateany such government, subdivision or authority.

RESIDENT. 1. For the purposes of this Convention, the term "“resident of a Contracting State" means ” refers to any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of 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 derived from sources in that StateState or from capital located in the same.

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, place of incorporation management or any other criterion of a similar nature. But this This term does not include include, however, any person who is liable to tax taxation in that State in respect only of income from sources in that State.

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, place of incorporation management or any other criterion of a similar nature. But this term does not include any person who is liable to tax in that in that State in respect only of income from sources in that StateState or capital situated therein.

RESIDENT. 1. For the purposes of this ConventionAgreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management, place of incorporation management, principal place of business 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.

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 the person's domicile, residence, place of management, place of incorporation or any other criterion of a similar nature. But this This term also includes that State and any political subdivision or local authority thereof, or any agency or instrumentality of that State, subdivision or local authority. 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.

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 managementhead or main office, place of incorporation management, or any other criterion of a similar nature. But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

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 managementincorporation, place of incorporation head or main office or any other criterion of a similar nature. But this term 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.

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 the person's domicile, residence, place of management, place of incorporation management or any other criterion of a similar nature. But this term nature but does not include any person who is liable to tax in that State in respect only of income from sources in that State.

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

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, place of incorporation 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.

RESIDENT. 1. For 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 taxation therein by reason of his domicile, residence, place of management, place of incorporation management or any other criterion of a similar nature. But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

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, place of incorporation 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 StateState or capital situated therein.

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 head or main office, place of management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. 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.

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, place of incorporation registration or any other criterion of a similar nature, and also includes that Contracting State and any political subdivision, central 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 StateContracting State or capital situated therein.

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, 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 State.

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, place of incorporation management or any other criterion of a similar naturenature 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.

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, place of incorporation 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 situated in that State.