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CHAPTER I - Income Tax
CHAPTER II - Registration Fees and Stamp Duties
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.



(1) An individual person shall be deemed to be a resident, within the meaning of this Convention, of the place where he or she has a "permanent home", this term refers to the center of vital interests, that is to say, the place with which the personal relations are closer.

(2) Where it is not possible to determine the residence according to the preceding paragraph of this Article, the individual shall be deemed to have his or her domicile in the Contracting State where he or she stays for a longer period. In case of equal duration of residence in both States, he or she shall be deemed to be domiciled in the State of which he or she is a national. If he or she is not a national of any of the two States, the higher administrative authorities of the states shall resolve settle the problem by mutual Agreement.

(3) For the purposes of this Convention, the domicile of bodies corporate shall be the place of the statutory registered office; the domicile of partnerships of individuals not having a legal personality, shall be the place of their effective management.