DT4153 - DT: Bulgaria: double taxation agreement, Article 4: Residence
- For the purposes of this Convention, the term 'resident of a
Contracting State' means:
- in the case of the United Kingdom, any person who, under the
law of the United Kingdom, is liable to tax therein by reason of
his domicile, residence, place of management or any other criterion
of a similar nature;
- in the case of Bulgaria, any individual who is a national of
Bulgaria, as well as any legal person which has its head office in
Bulgaria or is registered therein.
- Where by reason of the provisions of paragraph (1) of this
Article an individual is a resident of both Contracting States,
then he shall be deemed to be a resident of the State with which
his personal and economic relations are closer (centre of vital
interests);
- if the Contracting State in which he has his centre of vital
interests cannot be determined, the competent authorities of the
Contracting States shall settle the question by mutual agreement.
- Where by reason of the provisions of paragraph (1) of this
Article a person other than an individual is a resident of both
Contracting States, then it shall be deemed to be a resident of the
State in which its place of effective management is situated.
