RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
Samples: Taxation Agreement
RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, . under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any of its political subdivision subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources situated in that State.
Appears in 1 contract
Samples: 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, place of registration or any other criterion of a similar nature nature, and also includes that State and any political subdivision subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.
Appears in 1 contract
Samples: 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 residence, domicile, residence, place of management effective management, or any other criterion of a similar nature nature, and also includes that State and any political subdivision subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.
Appears in 1 contract
Samples: Agreement
RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature and also includes that State and any political subdivision or local authority thereofnature. 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 StateState or capital situated therein.
Appears in 1 contract
Samples: 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 political subdivision 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.
Appears in 1 contract
Samples: 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 nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources situated in that State.
Appears in 1 contract
Samples: Agreement
RESIDENT. 1. For the purposes of this AgreementConvention, the term "«resident of a Contracting State" » means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management management, place of incorporation (registration) or any other criterion of a similar nature and also includes nature. However, in the case of a partnership or estate the term applies only to the extent that State and any political subdivision the income derived by such partnership or local authority thereof. This term, however, does not include any person who estate is liable subjected to tax in that State as the income of a resident, either in respect only its hands or in the hands of income from sources in that Stateits partners.
Appears in 1 contract
Samples: internationaltaxtreaty.com
RESIDENT. 1l . For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
Samples: Agreement
RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature and also includes that State and any political subdivision 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 StateState or capital situated therein.
Appears in 1 contract
Samples: gra.gov.gh
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 political subdivision 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 StateState or capital situated therein.
Appears in 1 contract
Samples: Agreement
RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that Contracting State in respect only of income arising from sources in that State.
Appears in 1 contract
Samples: internationaltaxtreaty.com
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 or political subdivision subdivisions or local authority thereofauthority. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
Samples: Agreement
RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature and also includes that State and any political subdivision or local authority thereofnature. 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 StateState or on capital situated therein.
Appears in 1 contract
Samples: Double Taxation Agreement
RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person persons who, under the laws of that State, is liable to tax therein by reason of his this domicile, residence, place of management or any other criterion of a similar nature and also includes that State and any political subdivision or local authority thereofnature. 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.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of registration, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision administrative-territorial subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State State, in respect only of income from sources in that StateState or capital situated therein.
Appears in 1 contract
Samples: 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 State, any political subdivision or subdivision, central and local authority thereofоr a statutory body there of. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
Samples: Agreement
RESIDENT. 1. For the purposes of this Agreement, the term "''resident of a Contracting State" '' means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.
Appears in 1 contract
Samples: www.rs.ge
RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState situated therein.
Appears in 1 contract
Samples: auditors.am
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 nature, and also includes that Contracting State and any political subdivision 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 Contracting State.
Appears in 1 contract
Samples: 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 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.
Appears in 1 contract
Samples: Agreement
RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature and also includes that State and any political subdivision political-administrative subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.
Appears in 1 contract
Samples: Agreement
RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision political- administrative subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.
Appears in 1 contract
Samples: 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, or any other criterion of a similar nature nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
Samples: 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 political subdivision administrative territorial subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.
Appears in 1 contract
Samples: 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, or any other criterion of a similar nature nature, and also includes that State and any political subdivision 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.
Appears in 1 contract
Samples: Agreement
RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState situated therein.
Appears in 1 contract
Samples: internationaltaxtreaty.com
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 county government, political subdivision or subdivision, local authority or statutory body thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
Samples: 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 reasons of his domicile, residence, place of management or any other criterion of a similar nature and also includes that State and any political subdivision or local authority thereofnature. 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 StateState or capital situated therein.
Appears in 1 contract
Samples: internationaltaxtreaty.com
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 State, a “Land” and any political subdivision subdivision or local authority thereofof that State or “Land". This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.
Appears in 1 contract
Samples: www.revenue.ie
RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature and also includes that State and any political subdivision or local authority thereofnature. This term, however, does But this term shall not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
Samples: 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 political subdivision sub-division or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.
Appears in 1 contract
Samples: www.incometaxindia.gov.in
RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature and also includes that State and any political subdivision political- administrative subdivision, or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.
Appears in 1 contract
Samples: Agreement
RESIDENT. 1. For the purposes of this Agreement, the term "''resident of a Contracting State" '' means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature and also includes that State and any political subdivision 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.
Appears in 1 contract
Samples: 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 political subdivision or administrative subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income or capital gains from sources in that State.
Appears in 1 contract
Samples: Signed On
RESIDENT. 1. For the purposes of this Agreement, the term "resident ―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 that person’s domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
Samples: cacollege.co.za
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 political subdivision subdivision or local authority 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.
Appears in 1 contract
Samples: 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 nature, and also includes that State and any political subdivision administrative-territorial subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.
Appears in 1 contract
Samples: Agreement
RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political subdivision subdivision or administrative-territorial subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.
Appears in 1 contract
Samples: 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, head office, place of registration or any other criterion of a similar nature nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.
Appears in 1 contract
Samples: Agreement
RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature nature, and also includes that State and any political 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.
Appears in 1 contract
Samples: www.taxfind.ie:443
RESIDENT. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management management, or any other criterion of a similar nature and also includes that State and any political subdivision or local authority thereofnature. This term, however, But this term does not include any person who is liable to tax in that State in respect only of income from sources situated in that State.
Appears in 1 contract
Samples: 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 effective management or any other criterion of a similar nature nature, and also includes that State and any political subdivision subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that StateState or capital situated therein.
Appears in 1 contract
Samples: www.esteri.sm
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 nature. A Contracting State itself, and any political subdivision subdivision or local authority thereof, shall be deemed to be a resident of that State. 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 StateState or property situated therein.
Appears in 1 contract
Samples: internationaltaxtreaty.com
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 nature, and also includes that State and or any political subdivision subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Appears in 1 contract
Samples: Model Tax Agreement