Where by reason of the. provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident of the State in which he has a permanent home available to him; (b) if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer (centre of vital interests); (c) if the State in which he has his centre of vital interests cannot be determined, or if he has no permanent home available to him in either State, he shall be deemed to be a resident of the State in which he has an habitual abode; (d) if the status of resident cannot be determined according to subparagraphs (a) to (c), the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 6 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement for the Avoidance of Double Taxation
Where by reason of the. provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows:
(a) he shall be deemed to be a resident of the State in which he has a permanent home available to him;
(b) ; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer (centre of vital interests);
(cb) if the State in which he has his centre of vital interests cannot be determined, or if he has no not a permanent home available to him in either State, he shall be deemed to be a resident of the State in which he has an habitual abode;
(dc) if the status he has an habitual abode in both States or in neither of resident cannot be determined according to subparagraphs (a) to (c)them, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 5 contracts
Sources: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement
Where by reason of the. provisions of paragraph 1 an individual is a resident of both Contracting States, then his status this case shall be determined as followsin accordance with the following rules:
(a) he shall be deemed to be a resident of the State in which he has a permanent home available to him;
(b) if he has a permanent home available to him in both States, he shall be deemed to be a resident of the Contracting State with which his personal and economic relations are closer closest (centre of vital interests);
(cb) if the Contracting State in which he has his centre of vital interests cannot be determined, or he shall be deemed to be a resident of the Contracting State in which he has an habitual abode;
(c) if he has no permanent home available to him an habitual abode in either Stateboth Contracting States or in neither of them, he shall be deemed to be a resident of the Contracting State in of which he has an habitual abodeis a national;
(d) if the status he is a national of resident cannot be determined according to subparagraphs (a) to (c)both Contracting States or neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 3 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
Where by reason of the. provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows:
(a) he shall be deemed to be a resident of the State in which he has a permanent home available to him;
(b) ; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer (centre center of vital interests);
(cb) if the State in which he has his centre center of vital interests cannot be determined, or if he has no not a permanent home available to him in either State, he shall be deemed to be a resident of the State in which he has an habitual abode;
(dc) if the status he has an habitual abode in both States or in neither of resident cannot be determined according to subparagraphs (a) to (c)them, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Sources: Double Taxation Avoidance Agreement
Where by reason of the. provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows:
(a) a. he shall be deemed to be a resident of the State in which he has a permanent home available to him;
(b) ; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer (centre of vital interests);
(c) b. if the State in which he has his centre of vital interests cannot be determined, or if he has no not a permanent home available to him in either State, he shall be deemed to be a resident of the Contracting State in which he has an a habitual abode;
(d) c. if the status he has a habitual abode in both Contracting States or in neither of resident cannot be determined according to subparagraphs (a) to (c)them, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Sources: Double Taxation Agreement
Where by reason of the. provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as followsfollows :
(a) he shall be deemed to be a resident of the State in which he has a permanent home available to him;
(b) ; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations relation are closer (centre of vital interests);
(cb) if the State in which he has his centre of vital interests intersts cannot be determined, or if he has no not a permanent home available to him in either State, he shall be deemed to be a resident of the State in which he has an habitual abode;
(dc) if the status he has an habitual abode in both States or in neither of resident cannot be determined according to subparagraphs (a) to (c)them, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract