Dual Resident Entities

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..... the Contracting Jurisdictions shall endeavour to determine by mutual agreement the Contracting Jurisdiction of which such person shall be deemed to be a resident for the purposes of the Covered Tax Agreement, having regard to its place of effective management, the place where it is incorporated or otherwise constituted and any other relevant factors. In the absence of such agreement, such person .....

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..... or the entirety of this Article not to apply to its Covered Tax Agreements; b) for the entirety of this Article not to apply to its Covered Tax Agreements that already address cases where a person other than an individual is a resident of more than one Contracting Jurisdiction by requiring the competent authorities of the Contracting Jurisdictions to endeavour to reach mutual agreement on a single .....

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..... and that set out the treatment of that person under the Covered Tax Agreement where such an agreement cannot be reached; e) to replace the last sentence of paragraph 1 with the following text for the purposes of its Covered Tax Agreements: In the absence of such agreement, such person shall not be entitled to any relief or exemption from tax provided by the Covered Tax Agreement. ; f) for the enti .....

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