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Untd A Emirates - Greece Tax Treaty (as amended by 2013 protocol) — Orbitax Tax Hub

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 4

Resident

(1) For the purposes of this Agreement, the term "resident of a Contracting State" means:

  • (a) in the case of the Hellenic Republic: any person who, under the laws of the Hellenic Republic, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, 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;
  • *(b) in the case of the United Arab Emirates: an individual who has his domicile in the United Arab Emirates and the United Arab Emirates nationality, and a company which is incorporated in the United Arab Emirates and has its place of effective management there.

*(2) For the purposes of the above paragraph:

  • (a) the United Arab Emirates and its political subdivisions or local governments shall be deemed to be residents of the United Arab Emirates.
  • (b) Government institutions shall be deemed, according to affiliation, to be residents of a Contracting State. Any institution shall be deemed to be a government institution which has been created by the government of one of the Contracting States or of its political subdivisions, or local governments, under public law for the fulfillment of public purposes, excluding non-profitable organizations.

(3) 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 only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests);
  • (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode;
  • (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national;
  • (d) if he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

(4) 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 Contracting State in which its place of effective management is situated.