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 Contracting State in which its head office is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 5 contracts
Sources: Double Taxation 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, then it shall be deemed to be a resident of the Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated , or if that cannot be determinedestablished, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 4 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, then it shall be deemed to be a resident of the Contracting State in which its head office place of management and control is situated. If the State in which its head office is situated cannot be determined, In case of doubts the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 3 contracts
Sources: Agreement for the Elimination 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 it shall be deemed to be a resident of the Contracting State in which its head office place of effective management is situated. If the State a place of effective management is considered as situated in which its head office is situated cannot be determinedboth Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 3 contracts
Sources: Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion, 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, then it shall be deemed to be a resident of the Contracting State in which its legal head office is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 3 contracts
Sources: Agreement on 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 it shall be deemed to be a resident of the Contracting State in which its place of head office is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
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 it shall be deemed to be a resident of the Contracting State in which its place of head office (place of effective management) is situated. If the State in which its head office is situated cannot be determined, 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, 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 it shall be deemed to be a resident of the Contracting State in which its place of head office or of effective management is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
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 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 Contracting State in which its place of head office (i. e. effective management) of its business is situated. If the State in which its head office is situated cannot be determined, the 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 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 Contracting State in which its place of registration of its head office is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 2 contracts
Sources: Income and Capital Tax Treaty, 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 it shall be deemed to be a resident of the Contracting State in which the control and management of its head office business is situatedexercised. If the State in which place of control and management of its head office is situated business cannot be determined, the 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, then it shall be deemed to be a resident of the Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated cannot be determined, In case of doubts the 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, 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 it shall be deemed to be a resident of the Contracting State in which the place of effective management of its head office business is situated. If However, where the State in which its head office is situated place of effective management of the business or such person cannot be determined, then the competent authorities of the Contracting States shall settle the question determine by mutual agreementagreement the State of which the said person shall be deemed to be a resident for the purposes of this Agreement.
Appears in 2 contracts
Sources: 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 it shall be deemed to be a resident of the Contracting State in which its place of head office (place of effective management) is situated. If the State in which its head office is situated cannot be determined, the 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, then it shall be deemed to be a resident of the Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated cannot be determinedIn case of doubt, the 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, 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 it shall be deemed to be a resident of the Contracting State in which its head or main office is situated. If the State in which its head office is situated cannot be determined, 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 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 Contracting State in which its head office is situated. If the State in which its head office is situated cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.
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 it shall be deemed to be a resident of the Contracting State in which its head office place of effective management is situated. If However, where such person has its place of effective management in one of the State in which States and its legal head office is situated cannot be determinedin the other State, then the competent authorities of the Contracting States State shall settle the question consult to determine by mutual agreementagreement whether the legal head office of such a person has to be considered as the actual place of effective management or not.
Appears in 1 contract
Where by reason. of the provisions of paragraph paragraphs 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 Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated cannot be determined, In case of doubts 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, then it shall be deemed to be a resident only of the Contracting State in which its head office is situated. If the State in which its head office effective place of management is situated cannot be determinedsituated. In case of doubts, 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, then it shall be deemed to be a resident only of the Contracting State in which its head office is situated. If the State in which its head office place of effective management is situated cannot be determinedsituated. In case of doubts, 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, then it shall be deemed to be a resident of the Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated canplace of effective management can not be determined, then 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, then it shall be deemed to be a resident of the Contracting State in which its head office place of effective and central management is situated. If the State in which its head office is situated place of effective and central management cannot be determined, 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, then it shall be deemed to be a resident of the Contracting State in which its head office place of management and control is situated. If the State in which its head office is situated cannot be determined, In case of doubts the competent authorities of the Contracting States State 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, then it shall be deemed to be a resident of the Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated cannot be determinedIn case of doubt, the competent authorities of the Contracting States shall settle resolve 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, then it shall be deemed to be a resident of the Contracting State in which its head registered office is situated. If the State in which its head office is situated cannot be determined, In case of doubts 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, then it shall be deemed to be a resident of the Contracting State in which its head registered office is situated. If the State in which its head office is situated cannot be determined, In case of doubts the competent authorities authorites of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Where by reason. of the provisions of paragraph paragraphs 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 Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated cannot be determined, In case of doubts 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, then it shall be deemed to be a resident of the Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated , or if that cannot be determinedestablished, 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, then it shall be deemed to be a resident of the Contracting State in which its head office place of effective management is situated. If the State in which its head office is situated cannot be determined, In case of doubts 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, then it shall be deemed to be a resident of the Contracting State in which its the place of effective management (i.e. head office office) is situated. If the State in which its head office is situated cannot be determinedShould any problem arise regarding this matter, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Appears in 1 contract
Sources: Income and Capital Tax Agreement