DT7302 - DT: France: double taxation agreement, Article 3: Fiscal domicile

This agreement applies for periods before the new comprehensive agreement has effect (see DT7250).

(1) For the purposes of this Convention, the term `resident of a Contracting State` means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature. But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

(2) Where by reason of the provisions of paragraph (1) an individual is a resident of both Contracting States, then this case shall be determined in accordance with the following rules:

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

(4) The term `resident of a Contracting State` and `resident of the other Contracting State` means a person who is a resident of the United Kingdom, or a person who is a resident of France, as the context requires.