(1) For the purposes of this Agreement, the term “resident of a Contracting State” means:
- (a) in the case of the Czech Republic:
- (i) any person who, under the laws of the Czech Republic, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature, and also includes the Czech Republic and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in the Czech Republic in respect only of income from sources in the Czech Republic.
- (b) in the case of Qatar:
- (i) any individual who has a permanent home, centre of vital interests or habitual abode in Qatar, and any company incorporated or having its place of effective management in Qatar, provided that such individual or company is not a resident of a third State. The term also includes the State of Qatar, any political subdivision, local authority, or statutory body thereof, and any entity directly or indirectly wholly owned by the State of Qatar or by one or more of the above-mentioned subdivisions, authorities or bodies.
(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, the competent authorities of the Contracting States shall endeavour to determine by mutual agreement the Contracting State of which such person shall be deemed to be a resident for the purposes of the Agreement, having regard to its place of effective management, the place where it is incorporated or otherwise constituted and any other relevant factors. In the absence of such agreement, such person shall not be entitled to any relief or exemption from tax provided by the Agreement.