Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 56 contracts
Sources: Agreement for the Elimination of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement on Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 33 contracts
Sources: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, Agreement for the Elimination of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 28 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 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement and determine the mode of application of the Convention to such person. In the absence of such agreement, for the purposes of the Convention, the person shall in each Contracting State be deemed not to be a resident of the other Contracting State.
Appears in 23 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall settle determine that the question person is a resident of a Contracting State for the purposes of this Agreement by mutual agreement.
Appears in 12 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement.
Appears in 11 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual agreementand to determine the mode of application of this Agreement to such person.
Appears in 9 contracts
Sources: Income Tax Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreementagreement and determine the mode of application of the Agreement to such person.
Appears in 8 contracts
Sources: Income Tax Treaty, Double Taxation Agreement, Double Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreementagreement and determine the mode of application of this Agreement to such person.
Appears in 8 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual agreementand to determine the mode of application of the Agreement to such person.
Appears in 7 contracts
Sources: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreementagreement and determine the mode of application of the Convention to such person.
Appears in 7 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall settle resolve the question by mutual agreement.
Appears in 7 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual or a company is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 5 contracts
Sources: Convention for the Avoidance of Double Taxation, Double Taxation Treaty, Convention for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall settle resolve the question problem by mutual agreement.
Appears in 5 contracts
Sources: Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavor to settle the question by mutual agreement.
Appears in 5 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall settle the question by mutual agreementagreement and determine the mode of application of this Agreement to that person.
Appears in 5 contracts
Sources: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement, Double Taxation Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall settle the question by mutual agreementagreement taking into account where the place of effective management is situated.
Appears in 4 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement.agreement and determine the mode of application of the Agreement to such person. Article 5
Appears in 4 contracts
Sources: Income Tax Agreement, Income Tax Agreement, Income Tax Agreement
Where by reason. of the provisions of paragraph 1 1, a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 4 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement.
Appears in 4 contracts
Sources: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual or a company is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreementagreement and determine the mode of application of the Agreement to such person.
Appears in 4 contracts
Sources: Taxation Agreement, Taxation Agreement, Taxation Agreement
Where by reason. of the provisions of paragraph 1 1, a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreementagreement in accordance with Article 25 of this Agreement.
Appears in 3 contracts
Sources: Agreement for Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 1, a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreementagreement and determine the mode of application of the Convention to such person.
Appears in 3 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual or a company is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual agreementand to determine the mode of application of the Convention to such person.
Appears in 3 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent compentent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 3 contracts
Sources: Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of South Africa for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of South Africa for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of South Africa for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
Where by reason. of the provisions of paragraph 1 1, a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 3 contracts
Sources: Income Tax Agreement, Income Tax Agreement, Agreement for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreementagreement and determine the mode of application of the Agreement to such person.
Appears in 3 contracts
Sources: Income Tax Treaty, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion, Income and Capital Gains Tax Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities Competent Authority of the Contracting States shall settle the question by mutual agreementconsent.
Appears in 3 contracts
Sources: Double Taxation Agreement, 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 a person other than an individual is a resident of both Contracting StatesParties, the competent authorities of the Contracting States Parties shall settle the question by mutual agreement.
Appears in 3 contracts
Sources: Agreement for the Elimination of Double Taxation, Agreement for the Elimination of Double Taxation, Double Taxation Relief Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreementagreement and determine the mode of application of the Convention to such person.
Appears in 3 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Income Tax Convention
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreementagreement due regard being had to the place of effective management of such person or any other relevant criterion.
Appears in 3 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement, taking into consideration in which State the place of effective management of such person is situated.
Appears in 3 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall settle the question by mutual agreement.. --------------------------------------------------------------------------------
Appears in 2 contracts
Sources: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities Competent Authorities of the Contracting States shall settle the question matter by mutual agreementagreement taking into account where the place of effective management is situated.
Appears in 2 contracts
Sources: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 1, a person other than an individual is a resident of both Contracting States, then the competent Competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreementagreement having regard to such factors as the place of effective management and the place of incorporation.
Appears in 2 contracts
Sources: Double Taxation Agreement, Convention for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual inpidual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 2 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual or a company is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual agreementquestion, and to determine the mode of application of the Convention to such person.
Appears in 2 contracts
Sources: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting StatesState, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 2 contracts
Sources: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 1, a person other than an individual or a company is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreementagreement and determine the mode of application of the Convention to such person.
Appears in 2 contracts
Sources: Agreement for Avoidance of Double Taxation of Income, Double Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting StatesState, then the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 2 contracts
Sources: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States question shall settle the question be settled by mutual agreement.
Appears in 2 contracts
Sources: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph paragraphs 1 and 2 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreementagreement and determine the mode of application of the Agreement to that person.
Appears in 2 contracts
Sources: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual or a company is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavor to settle the question by mutual agreementagreement and to determine the mode of application of the Convention to such person.
Appears in 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Tax Convention
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent Competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the question shall be settled by the competent authorities of the Contracting States shall settle the question by mutual agreementStates.
Appears in 2 contracts
Sources: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavor to settle the question by mutual agreementand to determine the mode of application of the Convention to such person.
Appears in 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Where by reason. of the provisions of paragraph 1 1, a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall Shall settle the question by mutual agreement.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the both 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 a person other than an individual is a resident of both Contracting States, then the competent authorities authority of the Contracting States shall settle the question by mutual agreementconsent.
Appears in 1 contract
Sources: Income Tax Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreementagreement and determine the mode of application of the Agreement to such person.
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall settle resolve the question of resident by mutual agreement.
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement.. Article 5
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreementagreement in accordance with the provisions of Article 25.
Appears in 1 contract
Sources: Income Tax Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of then the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement, taking into c side ration in which State the place of effective management of such person is situated.
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall settle the question by mutual agreement, due regard being had to any relevant criterion.
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual agreement.and to determine the mode of application of this Agreement to such person. --------------------------------------------------------------------------------
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 1, a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual or a company is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavor to settle the question by mutual agreementagreement and determine the mode of application of the Convention to such person.
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States State shall endeavor to settle the question by mutual agreement.
Appears in 1 contract
Sources: Double Taxation Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreementagreement and determine the mode of application of the agreement to such person.
Appears in 1 contract
Sources: Double Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement, having regard to its place of head or main office, its place of effective management, the place where it is incorporated or otherwise constituted and any other relevant factors.
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreementagreement and determine the mode of application of this Agreement to such person.
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreementagreement in accordance with Article 25 of this Agreement.
Appears in 1 contract
Sources: Double Taxation Agreement
Where by reason. of the provisions of paragraph 1 1, a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreementagreement keeping in view its place of incorporation, place of effective management and other relevant factors.
Appears in 1 contract
Sources: Double Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual agreementand to determine the mode of application of the Convention to such person.
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavor to settle the question by mutual agreementand to determine the mode of application of the Agreement to such person.
Appears in 1 contract
Sources: Double Taxation Agreement
Where by reason. of the provisions of paragraph 1 1, a person other than an individual is a resident of both Contracting States, the competent then thme pceotent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavor to settle the question by mutual agreement.
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreementagreement having regard to such factors as the place of effective management and the place where it is incorporated.
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person person, other than an individual is a resident of both Contracting States, States the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual agreementquestion.
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the both 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 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement, due regard being had to its place of effective management, its place of registration, its place of establishment or any other relevant criterion.
Appears in 1 contract
Sources: Double Taxation Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreementagreement on a case by case basis.
Appears in 1 contract
Sources: Double Taxation Avoidance Agreement
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual agreementand to determine the mode of application of the Agreement to such person, taking in consideration that the place of effective management is the main factor in this case.
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall settle resolve the question issue by mutual agreement.
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreementagreement having regard to such factors as the place of central management and control and the place of incorporation.
Appears in 1 contract
Sources: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual agreementand to determine the mode of application of this Convention to such person.
Appears in 1 contract
Sources: Income and Capital Tax Convention
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour in order to settle the question by mutual agreementagreement and determine the mode of application of the Convention to such person.
Appears in 1 contract
Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreementagreement having regard to its place of effective management, place of main or head office, place of incorporation, or any other relevant factors.
Appears in 1 contract