Resident

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... nclude any person who is liable to tax in that State only in respect of income from sources in that State or property situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both ContractingStates, 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; .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... agreement. 3. Where by reason of the provisions of paragraph 1 if 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 in which its place of effective management is situated. If the State in which its place of effective management is situated cannot be determined, then the competent authorities of the Contracting States .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X