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ARTICLE 4

Resident

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

  • (a) in the case of the Principality of Liechtenstein:
    • (i) any person who, under the laws of Liechtenstein, 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:
    • (i) an individual who has his domicile in the United Arab Emirates and is a national of the United Arab Emirates as well as any other individual who has his habitual abode or centre of vital interests in the United Arab Emirates; and
    • (ii) any person other than an individual that is incorporated or has its place of effective management in the United Arab Emirates or is otherwise recognized as such under the laws of the United Arab Emirates or any political subdivision, local Government or local authority thereof.

(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 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.

(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 only of the State in which its place of effective management is situated.