Resident

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..... sub-division or local authority thereof. 2. A person is not a resident of a territory for the purposes of this Agreement if that person is liable to tax in that territory in respect only of income from sources in that territory, provided that this paragraph shall not apply to individuals who are residents of the territory referred to in paragraph 3( b ) of Article 2, as long as resident individua .....

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..... ( c ) if he has a habitual abode in both territories or in neither of them, the competent authorities of the territories shall settle the question by mutual agreement. 4 . Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both territories, then it shall be deemed to be a resident only of the territory in which its place of effective management is .....

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