Resident

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....subdivision or local authority thereof. But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State, or capital situated therein. 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: 1) he shall be deemed to be a resident on....

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....ion by mutual agreement. 3. [REPLACED by paragraph 1 of Article 4 of the MLI] [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 only 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 de....