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 administrative-territorial unit or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 2 contracts
Sources: 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 administrative-territorial unit or local authority thereof. This term, however, But this term does not include any person who 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 management or any other criterion of a similar nature, nature and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 2 contracts
Sources: Double Taxation Avoidance Agreement, Income Tax 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 incorporation or any other criterion of a similar nature, nature and also includes that State and any administrative-territorial unit political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 2 contracts
Sources: Income Tax Agreement, Income and Capital Gains Tax 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 administrative-territorial unit or political subdivision, local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 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 and any administrative-territorial unit 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, Income Tax 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 effective management, place of head office or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit 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 of a similar nature, and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, However this term does not include any person who is liable to tax in that a Contracting State in respect only of income from sources in that State or capital situated thereinState.
Appears in 2 contracts
Sources: Agreement Between the Republic of Indonesia and the Kingdom of Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Republic of Indonesia and the Kingdom of Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
RESIDENT. 1. For the purposes of this 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 administrative-territorial unit or political subdivision, local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 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 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 administrative-territorial unit 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 property 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 or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Income and Capital Tax 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 administrative-territorial unit or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
Sources: Double Taxation Agreement
RESIDENT. 1. For the purposes of this Agreement, the term “" resident of a Contracting State” State " means any person who, under the laws of that StateState , 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 administrative-territorial unit or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 1 contract
RESIDENT. 1. For the purposes of this 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, residenceresi- dence, place of incorporation, place of management or any other criterion of a similar nature, nature and also includes that State and any administrative-territorial unit political subdivision or local authority thereof. This term, term however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
Sources: Double Tax 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 administrative-territorial unit or local authority thereofState. This term, however, does not include any person who is liable li- able 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 registration, place of management, principal place of business or any other criterion of a similar nature, and also includes that State and or any administrative-territorial unit or local authority authorities thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
RESIDENT. 1. 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 head or main office or any other criterion of a similar nature, and also includes that Contracting State and any administrative-territorial unit 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 residence, 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 administrative-territorial unit 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 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 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 administrative-territorial unit or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State 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, legal head office, place of management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit political subdivision or local authority thereof. , 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: Income Tax 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 administrative-territorial unit or local authority thereof. This term, however, term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
Sources: Income Tax 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 administrative-territorial unit subdivision or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital property situated therein.
Appears in 1 contract
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 administrative-territorial unit 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 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 administrative-territorial unit or local authority thereofauthorities. This term, however, term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 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 law of that State, is liable to tax taxation therein by reason of his domicile, residence, place of management or any other criterion of a similar nature. However, and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, this term does not include any person the residents who is are liable to tax in that State only in respect only of income from sources in that State or capital properties situated thereinin that 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 that person's domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit political subdivision or local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 1 contract
Sources: Income Tax 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 administrative-territorial unit 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
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, and also includes that State and any administrative-territorial unit 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
Sources: Income and Capital Tax 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 incorporation or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income or capital gains from sources in that State or capital situated therein.
Appears in 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 administrative-territorial unit 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 that person’s domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit political subdivision or local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 1 contract
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, under in accordance with the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion criteria of a similar this nature, and also as well as includes that State and any administrative-territorial unit subdivision or a local authority thereofauthority. This termHowever, however, the term does not include any person who is liable to tax in that State in respect only of income from sources in that State or against 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 State, is liable to tax therein by reason of his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit 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 State, is liable to tax therein by reason of his domicile, residence, registered office, place of management effective management, or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit political subdivision or local authority thereof. 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, duration of his stay, place of management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 1 contract
RESIDENT. 1. For the purposes of this 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 administrative-territorial unit or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 1 contract
Sources: Income Tax 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 (registered office), place of management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 1 contract
RESIDENT. 1. For the purposes of this Agreement, the term “« resident of a Contracting State” State » means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management mana- gement or any other criterion of a similar nature, nature and also includes that State and any administrative-territorial unit political subdivision or local authority thereofthe- reof. 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: Tax Treaty
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 registration, place of management, principal place of business or any other criterion of a similar nature, and also includes that State and or any administrative-territorial unit or local authority authorities thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, who under the laws of that State, the State is liable to tax therein by reason of his residence, domicile, residenceplace of registration, place of management or any other criterion of a similar nature, and also includes that State and or any administrative-territorial unit or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinpolitical subdivision.
Appears in 1 contract
RESIDENT. 1. For the purposes of this Agreement, 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 management effective management, place of incorporation or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinstate.
Appears in 1 contract
Sources: Income Tax 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 administrative-territorial unit 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 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, nature and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital property 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 administrative-territorial unit 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 property situated therein.
Appears in 1 contract
RESIDENT. 1. For the purposes purpose of this Agreement, the term “resident of a Contracting State” means any a person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of registration, place of management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit or local authority thereof. 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: Income and Capital Tax 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, place of management, principal place of business or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated 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 administrative-territorial unit or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State 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 incorporation or registration, place of management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit or local authority political subdivision 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 registration, place of management, or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 1 contract
Sources: Income Tax 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 administrative-political or administrative territorial unit 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 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 administrative-territorial unit or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital (property) situated therein.
Appears in 1 contract
Sources: Income and Capital Tax 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, place of effective management, place of management, principal place of business or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated 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 incorporation, place of management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit political subdivision or local authority thereof. 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 State, is liable to tax therein by reason of his domicile, residence, legal head office (registered office), place of management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit or local authority thereof. 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 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 registration or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 1 contract
RESIDENT. 1. For the purposes of this 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, place of registration, residence, place of management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit political subdivision or local authority thereof. 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 (property) situated therein.
Appears in 1 contract
Sources: Income and Capital Tax 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 registration, place of management, or any other criterion of a similar nature, and . The term "resident of a Contracting State" also includes that State or its local authorities or a legal person organized under the laws of a Contracting State and any administrative-territorial unit or local authority thereofthat is generally exempt from tax in that State. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 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 administrative-territorial unit 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: Income Tax Treaty
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means 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, nature and also includes that State and any administrative-territorial unit political 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 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 administrative-territorial unit or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 1 contract
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, any of its “Länder” and any administrative-territorial unit of their political subdivisions or local authority thereofauthorities. 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 that person's domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit political subdivision or local authority thereof. 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 incorporation or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 1 contract
Sources: Income and Capital Tax Agreement
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws law of that State, State is liable to tax therein taxes in that State by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit administrative 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 1 contract
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any a person who, under the laws of that State, 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 administrative-territorial unit or local authority thereof. This term, however, ; the term 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 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 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 administrative-territorial unit or local authority autho- rity 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, nature and also includes that State and any administrativepolitical-territorial unit 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 administrative-territorial unit or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.reason
Appears in 1 contract
Sources: Employment 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 administrative-territorial unit or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated 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 State, a Land and any administrative-territorial unit 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 management, place of incorporation or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit 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 head office, place of incorporation or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit or State, a local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 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 administrative-territorial unit or political subdivision, local authority or a statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 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 administrative-territorial unit or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated 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 incorporation, place of management or any other criterion of a similar nature, nature and also includes that State and any administrative-territorial unit 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 administrative-territorial unit 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: Income Tax 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 in that State by reason reasons of his domicile, permanent residence, place of management headquarters, or any other similar criterion of a similar natureand includes the State itself as well as its administrative bodies and local authorities. However, and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, this term does not include any person who is liable to tax in that State in respect only by reasons of income from sources in that State or capital property situated thereinin that State.
Appears in 1 contract
Sources: Income and Capital Tax 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 effective management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
Sources: Income Tax 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 administrative-territorial unit 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: Income Tax Agreement
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 registration, place of management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
Sources: Income Tax 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, nature and also includes that State and any administrative-territorial unit 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: Income Tax 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 management or place of registration or any other criterion of a similar nature, and also includes that Contracting State and any administrative-territorial unit political subdivision or local authority or statutory body 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 residence, domicile, residence, place of management effective management, or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 1 contract
Sources: Income and Capital Tax 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 registration, place of incorporation, or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit 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
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 that person’s domicile, place of registration, residence, place of management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit political subdivision or local authority thereof. 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 (property) situated therein.
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, and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.his
Appears in 1 contract
Sources: Employment 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 Contracting 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 Contracting State and any administrative-territorial unit political subdivision or local authority or statutory body 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. 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 administrative-territorial unit or State, local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 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 administrative-territorial unit or local authority thereof. This term, however, But this term does not include any a person who is liable to tax in that State in respect only of income from sources in that State or on 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 (or registration), place of management or any other criterion of a similar nature, and . The term also includes that State and any administrative-territorial unit or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated 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 management or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit administrative or political subdivision or local authority thereof. This term, however, term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Appears in 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 administrative-territorial unit 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
Sources: Income Tax Agreement
RESIDENT. 1. For the purposes of this Agreement, the term “"resident of a Contracting State” " means any person who, who under the laws of that State, the State is liable to tax therein by reason of his domicile, residence, place of management registration, or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit 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
Sources: Income Tax 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, 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 administrative-territorial unit 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, place of management management, place of registration, or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit political 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 therein.
Appears in 1 contract
RESIDENT. 1. For the purposes of this Agreement, the term “resident of a the Contracting 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, registered office or any other criterion of a similar nature. However, and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, the term does not include any person who is liable to tax in that State in respect only of income from sources in that State 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, who under the laws of that State, State is liable to tax therein by reason of his residence, domicile, residenceplace of registration, place of management or any other criterion of a similar nature, and also includes that State and State, any administrative-territorial unit 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: Agreement for the Avoidance of Double Taxation and Fiscal Evasion 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 administrative-territorial unit political subdivision or local authority thereof. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated thereinState.
Appears in 1 contract
Sources: Income Tax 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 administrative-territorial unit 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: Income and Capital Tax 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 registration, residence or any other criterion of a similar nature, and also includes that State and any administrative-territorial unit or local authority thereof. This term, however, 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 property situated therein.
Appears in 1 contract
Sources: Income and Property Tax Agreement