Fiscal domicile

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....milar nature. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his residential status shall be determined in accordance with the following rules :-- (a) he shall be  deemed to be a resident of the ContractingState in which he has a permanent home available to him. If he has a permanent home available to him in both Con....

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....s shall settle the question by mutual agreement. 3. Where by reason of the provisions of paragraph 1 a company is a resident of both Contracting States, then this case shall be determined in accordance with the following rules: (a) it shall be deemed to be a resident of the ContractingState of which it is a national; (b) if it is a national of neither of the Contracting States, ....