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ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡΙΛΙΟΥ
1984
States for the purposes of its tax, but
Ιη
the
case
ο! ίηCΟΜθ
derived or paid
by
a partnership,
estate, or truet this term appl1es only to the
8xtent that the
ίηCΟΜθ
derived
by
Buch person is
8ubjeot to United states tax
βθ
the income
ο!
a
resident either
ίη
its hands
οτ ίη
the hands
ο!
1t8 partners or heneficiaries.
(2)
Wbere bl reaeon of the provisions of paragraph (1)
8Δ
LDd1vldual
19
a resident of both Contracting States:
421
(a)
Ββ
8hal1 be deemed to be a reeident of that
COAtraoting State
ίη
whioh he maintains his penaanent
boae.
ΣΙ
he has a permanent home
ίη
both Contracting
l\at88 or
ίη
neither of the Contracting States, he
shal1 be deemed to be a resident
ο!
that Contracting
State with which his personal
and
economic relations
βΤθ
closer (center
ο!
vital interests);
(b) If his center of vital interests i8
ίη
neither
ο!
the Contracting States or cannot be determined,
he
θhaΙΙ
be deemed to be a resident of that
Contracting State
ίη
which he has a habitual abode;
(ο)
If he has a habitual abode
ίη
both Contracting
States or
ίη
neither of the Contracting States,
he shal1 be deemed to be a resident of the Contracting
State of which he 18 a oitizen; and
(d) If he i8 a citizen
ο!
both Contracting States
or
ο!
neither Contracting State the competent
authorities of the Contracting States shall settle
the question by mutual agreement.
(3)
An
lndividual who 1s deemed to be a re8ident
ο!
a
Ooatracting state and not a resident
ο!
the other Contraoting
8tate b7 reason of the
p~oνίθίoηθ
of paragraph (2) shall be
t88Med to be a resident only of the first-mentioned Contractiqg
It.te for
al1
purposes of this Convention, inoluding Article
4
(GeAera1
Ru1es of Taxation).
(4)
Where
by
reason of the provisions of paragraph (1) a
JerwoA
other than an ind1vidual or a corporation 1s a resident
.ι
both
CΟΔtractίng
States, the competent authorities of the
ΟοΔtrao'1Ω&
States shal1 by mutual agreement endeavor to
.."1.
'h8 question and to determine the mode of application
.,
,.. Ooav8ntion to such person.