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 determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this Agreement.
Appears in 8 contracts
Sources: Double Taxation Avoidance Agreement, Double Taxation 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 endeavour to determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this AgreementConvention. In the absence of a mutual agreement by the competent authorities of the Contracting States, the person shall not be considered a resident of either Contracting State for the purposes of claiming any benefits provided by the Convention, except those provided by Articles 21, 22 and 23.
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 determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this AgreementConvention. In the absence of a mutual agreement by the competent authorities of the Contracting States, the person shall not be considered a resident of either Contracting State for the purposes of claiming any benefits provided by the Convention, except those provided by Articles 23 and 24.
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 determine his residential status by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this Agreementagreement.
Appears in 5 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, then the competent authorities of the Contracting States shall endeavour to determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this AgreementConvention. In the absence of a mutual agreement by the competent authorities of the Contracting States, the person shall not be considered a resident of either Contracting State for the purposes of claiming any benefits provided by the Convention, except those provided by Articles 22, 23 and 24.
Appears in 4 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, 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 determine endeavour by mutual agreement to deem, for purposes of the Contracting State of which that Convention, the person shall be deemed to be a resident for the purposes of this Agreementone Contracting State only.
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 seek to determine by mutual agreement through consultation the Contracting State of which that the person shall be deemed to be a resident for the purposes of this AgreementConvention, and, if they are unable so to determine, such person shall not be considered to be a resident of either Contracting State for purposes of enjoying benefits under this Convention.
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 determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this AgreementConvention. In the absence of a mutual agreement by the competent authorities of the Contracting States, the person shall not be considered a resident of either Contracting State for the purposes of claiming any benefits provided by the Convention, except those provided by Articles 21, 23 and 24.
Appears in 3 contracts
Sources: Tax Agreement, Tax Agreement, 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 of the Contracting States shall determine by mutual agreement the Contracting State of which that person it shall be deemed to be a resident for of the purposes Contracting State under the laws of this Agreementwhich it derives its status as such.
Appears in 3 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, then the competent authorities of the Contracting States shall endeavour to determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this Agreement. In the absence of a mutual agreement by the competent authorities of the Contracting States, the person shall not be considered a resident of either Contracting State for the purposes of claiming any benefits provided by the Agreement, except those provided by Articles 21, 23 and 24.
Appears in 3 contracts
Sources: Double Taxation Agreement, Double Taxation 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 determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this AgreementConvention. In the absence of a mutual agreement by the competent authorities of the Contracting States, the person shall not be considered a resident of either Contracting State for the purposes of claiming any benefits provided by the Convention, except those provided by Article 22, Article 24 and Article 25.
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 its status shall determine be determined by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this Agreementagreement.
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 of the Contracting States shall endeavour to determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this Agreement. In the absence of a mutual agreement by the competent authorities of the Contracting States, the person shall not be considered a resident of either Contracting State for the purposes of claiming any benefits provided by this Agreement, except those provided by Articles 23, 24 and 25.
Appears in 2 contracts
Sources: Double Taxation 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 State shall determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this AgreementConvention.
Appears in 2 contracts
Sources: Double Taxation Avoidance Agreement, 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, then the competent authorities of the Contracting States shall determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this AgreementConvention.
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 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this Agreement. In the absence of a mutual agreement by the competent authorities of the Contracting States, the person shall not be considered a resident of either Contracting State for the purposes of claiming any benefits provided by the Agreement, except those provided by Articles 23 and 24.
Appears in 2 contracts
Sources: Double Taxation 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 determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this Agreement. In the absence of a mutual agreement by the competent authorities of the Contracting States, the person shall not be considered a resident of either Contracting State for the purposes of claiming any benefits provided by the Agreement, except those provided by paragraph 2 of Article 22, Article 24 and Article 25.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, 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 endeavour to determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this AgreementConvention, having regard to the place of its head or main office, its place of effective management and any other relevant factors.
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 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this AgreementConvention, having regard to the place of its head or main office, its place of effective management and any other relevant factors.
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 a person other than an individual is a resident of both Contracting States, then its status shall be determined in accordance with the competent authorities of the Contracting States shall determine by mutual agreement the Contracting State of which that person following rules:
(a) it shall be deemed to be a resident for of the purposes Contracting State of this Agreementwhich it is a national;
(b) if it is a national of neither of the Contracting States, it shall be deemed to be a resident of the Contracting State in which its place of effective management is situated.
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, States then the competent authorities of the Contracting States shall determine determined by mutual agreement the Contracting State state of which that person shall be deemed to be a resident for the purposes of this AgreementConvention .
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 of the Contracting States shall endeavour to determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this Agreement. In the absence of a mutual agreement by the competent authorities of the Contracting States, the person shall not be considered a resident of either Contracting State for the purposes of claiming any benefits provided by the Agreement, except those provided by Articles 21, 22 and 23.
Appears in 2 contracts
Sources: Tax 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 endeavour to determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this Agreement. In the absence of a mutual agreement by the competent authorities of the Contracting States, the person shall not be considered a resident of either Contracting State for the purposes of claiming any benefits provided by the Agreement, except those provided by Articles 22, 23 and 24.
Appears in 2 contracts
Sources: Double Taxation Agreement, 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 of the Contracting States shall endeavour to determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this AgreementConvention. In the absence of a mutual agreement by the competent authorities of the Contracting States, the person shall not be considered a resident of either Contracting State for the purposes of claiming any benefits provided by the Convention, except those provided by Articles 23, 25 and 26.
Appears in 2 contracts
Sources: Double Taxation Convention, Income and Capital Tax Convention
Where by reason. of the provisions of paragraph 1 1, a person other than an individual is a resident of both Contracting States, it shall be deemed to be a resident of the State in which it is incorporated; if the person under the foregoing criterion is still a resident of both Contracting States, then the competent authorities of the Contracting States shall determine settle the question by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this Agreementagreement.
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 competent authorities of the Contracting States shall endeavour to determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this Agreement. In the absence of a mutual agreement by the competent authorities of the Contracting States, the person shall not be considered a resident of either Contracting State for the purposes of claiming any benefits provided by the Agreement, except those provided by Articles 22, 24 and 25.
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 of the Contracting States shall determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this AgreementConvention.
Appears in 1 contract
Sources: 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, then the competent authorities of the Contracting States shall determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this Agreementthe Convention.
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 it shall be deemed to be a resident of the State under the laws of which it derives its status as such. The competent authorities of the Contracting States shall determine endeavour to settle the question by mutual agreement and determine the Contracting State mode of which that person shall be deemed application of the Convention to be a resident for the purposes of this Agreementsuch 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 endeavour to determine by mutual agreement the Contracting State of which that such person shall be deemed to be a resident for the purposes of this Agreementthe Convention, having regard to 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, then the competent authorities of the Contracting States shall determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this AgreementConvention.
Appears in 1 contract
Sources: Agreement for Avoidance of Double Taxation and 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, then the competent authorities of the Contracting States shall determine settle the question of residence by mutual agreement the Contracting State agreement, due regard being had to its registered office, place of which that person shall be deemed to be a resident for the purposes of this Agreementeffective management or incorporation.
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 endeavour to determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this AgreementConvention, having regard to all relevant factors.
Appears in 1 contract
Sources: Double Taxation 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 authorities of the Contracting States shall determine by mutual agreement the Contracting State of which that such person shall be deemed to be a resident for the purposes of this the 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, then the competent authorities of the Contracting States shall endeavour to determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this AgreementConvention. In the absence of a mutual agreement by the competent authorities of the Contracting States, the person shall not be considered a resident of either Contracting State for the purposes of claiming any benefits provided by the Convention, except those provided by Articles 25, 26 and 27.
Appears in 1 contract
Sources: Double Taxation Convention