TMI BlogResidentX X X X Extracts X X X X X X X X Extracts X X X X ..... e any person who is liable to tax in that State in respect only of income from sources or capital situated in the Contracting State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident of the Contracting State in which he has a permanent home available ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion by mutual agreement.
3. 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 in which its place of effective management is situated.
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