二重課税防止条約（居住者判定に関する規定）
令和7年7月4日|p.24
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3. Where by reason of the provisions of paragraph 1 a person other than an individual
is a resident of both Contracting States, the competent authorities of the Contracting
States shall endeavour to determine by mutual agreement the Contracting State of which
such person shall be deemed to be a resident for the purposes of this Convention, having
regard to its place of head or main office, its place of effective management, the place
where it is incorporated or otherwise constituted and any other relevant factors. In the
absence of such agreement, such person shall not be entitled to any relief or exemption
from tax provided by the Convention