(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, place of incorporation or any
other criterion of a similar nature, and also includes that State
and any political subdivision or local authority of a “Land” or a
Contracting State. This term, however, does not include any
person who is liable to tax in that Contracting State only if he
derives income or capital gains from sources therein or capital
situated therein.
(2) Where by reason of the provisions of paragraph 1 an indi-
vidual is a 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 Contract-
ing 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 does not have a per-
manent 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) if he 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.
(3) Where by reason of the provisions of paragraph 1 a per-
son other than an individual is a resident of both Contracting
States, then it shall be deemed to be a resident only of the State
in which its place of effective management is situated.
(4) If the place of effective management of a shipping enter-
prise is aboard a ship, then it shall be deemed to be situated in
the Contracting State in which the home harbour of the ship is
situated.
Citation to select or copy
Germany / United Kingdom; BGBl. 2010 II S. 1333; edition de-united-kingdom-2010-base | BGBl. 2010 II S. 1333 | Signed: 2010-03-30 | Gazette publication: 2010-11-23; article 4; English; unreviewed source text, current applicability unverified; /editions/de-united-kingdom-2010-base/en/articles/article-4/
Disclaimers
Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.
Language switching retains source identifiers only. This is not reviewed legal or translational equivalence.
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Noindex is not access control. This is a research preview, not a statement of authoritative or current law.
de-united-kingdom-2010-base | BGBl. 2010 II S. 1333 | Signed: 2010-03-30 | Gazette publication: 2010-11-23
Text available here
Deutsch, English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Gazette publication date
2010-11-23
Provenance
agent source-triage of pinned original; neither date is treaty entry/application
Signature date
2010-03-30
Edition notes and known limitations
Original source edition; not a verified current-law consolidation. Unknown. No current-law consolidation, effective-period determination, MLI application, or complete amendment-chain verification has been performed. Original publication year is not a current applicability date. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
The protocol printed with this agreement is separately preserved in source supplements; it has not been merged into treaty articles. Subsequent protocols, amendments, MLI effects, replacements and suspensions are unresolved. This is not a consolidated current-law instrument. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2014-03-17; entry into force: 2015-12-29; general application from: 2016-01-01; limit: Exact tax-specific application remains for protocol review. / amending-protocol; signature date: 2021-01-12; entry into force: 2021-12-17; general application from: 2022-01-01; limit: Exact tax-specific application remains for protocol review.
German and English versions are present in the source and are identified by the signing clause. Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-united-kingdom-2010-base/. PDF page links identify pages, not verified paragraph correspondence.