Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.
ARTICLE 1
Resident
(1) This Convention shall apply to persons who are residents of one or both of the Contracting States.
(2) For the purposes of this Convention, the term "resident of a Contracting State" means any person who is liable to tax in that Contracting State by reason of his domicile, residence, place of head or main office, place of management or any other criterion of a similar nature.
(3) Where by reason of the provisions of paragraph (2), a person is a resident of both Contracting States, then the competent authorities of the Contracting States shall determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this Convention.