租税条約第4条（居住者）
令和7年7月4日|p.23
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ARTICLE4
RESIDENT
1. For the purposes of this Convention, the term "resident of a Contracting State"
means any person who, under the laws of that Contracting State, is liable to tax therein
by reason of his domicile, residence, place of head or main office, place of management,
place of incorporation or any other criterion of a similar nature, and also includes that
Contracting State and any political subdivision or local authority thereof as well as a
recognised pension fund of that Contracting State. This term, however, does not include
any person who is liable to tax in that Contracting State in respect only of income from
sources in that Contracting State.
2. Where by reason of the provisions of paragraph 1 an individual0.0a resident of
both Contracting States, then his status shall be determined as follows:
(a) he shall be deemed to be a resident only of the Contracting State in which
he has a permanent home available to him; if he has a permanent home
available to him in both Contracting States, he shall be deemed to be a
resident only of the Contracting State with which his personal and
economic relations are closer (centre of vital interests):
(b) if the Contracting State in which he has his centre of vital interests cannot
be determined, or if he has not a permanent home available to him in either
Contracting State, he shall be deemed to be a resident only of the
Contracting State in which he has an habitual abode:
(c) ifhe has an habitual abode in both Contracting States or in neither of them,
he shall be deemed to be a resident only of the Contracting State of which
he is a national:
(d) if he is a national of both Contracting States or of neither of them, the
competent authorities of the Contracting States shall settle the question by
mutual agreement.