- 1
- An individual living aboard a ship without any real domicile in either of the Contracting Parties shall be deemed to be a resident of the Contracting in which the ship has its home harbour.
- 2
- In considering cases which fall within paragraph 4 of Article 4 of the Agreement the competent authorities shall have regard to:
-
- a)where the senior management of the person is carried on;
- b)where the meetings of the board of directors or equivalent body are held;
- c)where the person’s headquarters are located;
- d)the extent and nature of the economic nexus of the person to each Contracting Party;
- e)whether determining that the person is a resident of one of the Contracting Parties but not of the other Contracting Party for the purposes of the Agreement would carry the risk of an improper use of the Agreement or inappropriate application of the domestic law of either Contracting Party.
