DT7703 - DT: The Gambia: double taxation agreement, Article 4: Fiscal domicile


(1) For the purposes of this Convention, the term `resident of a territory` means subject to the provisions of paragraph (2) of this Article, any person who, under the law of that territory, is liable to taxation therein by reason of his domicile, residence, place of management or any other criterion of a similar nature. The terms `resident of the United Kingdom` and `resident of The Gambia` shall be construed accordingly.

(2) Where by reason of the provisions of paragraph (1) of this Article a person other than an individual is a resident of both territories, then it shall be deemed to be a resident of the territory where its business is managed and controlled.