Interface language: English. Document language: English (EN).
de-south-africa-2008-not-in-force · EN
EN · Physical source page 6
Complete native lines of physical PDF page 6. Page-number furniture is retained. Source coordinate order, not a facsimile or human-verified typography.
PDF 6 · en-pdf-006-line-002k) the term ”competent authority” means:
PDF 6 · en-pdf-006-line-004in the case of the Federal Republic of Germany the Federal Ministry of
PDF 6 · en-pdf-006-line-005Finance or the agency to which it has delegated its powers;
PDF 6 · en-pdf-006-line-007in the case of South Africa the Commissioner for the South African
PDF 6 · en-pdf-006-line-008Revenue Service or an authorised representative.
PDF 6 · en-pdf-006-line-009(2) As regards the application of the provisions of this Agreement at any time by a
PDF 6 · en-pdf-006-line-010Contracting State‚ any term not defined therein shall‚ unless the context otherwise
PDF 6 · en-pdf-006-line-011requires‚ have the meaning that it has at that time under the law of that State for the
PDF 6 · en-pdf-006-line-012purposes of the taxes to which this Agreement applies‚ any meaning under the applicable
PDF 6 · en-pdf-006-line-013tax laws of that State prevailing over a meaning given to the term under other laws of that
PDF 6 · en-pdf-006-line-015Article 4
PDF 6 · en-pdf-006-line-016Resident
PDF 6 · en-pdf-006-line-017(1) For the purposes of this Agreement‚ the term ”resident of a Contracting State” means
PDF 6 · en-pdf-006-line-018any person who‚ under the laws of that State‚ is liable to tax therein by reason of that
PDF 6 · en-pdf-006-line-019person’s domicile‚ residence‚ place of management or any other criterion of a similar
PDF 6 · en-pdf-006-line-020nature‚ and also includes that State itself‚ a Land and any political subdivision or local
PDF 6 · en-pdf-006-line-021authority thereof. This term‚ however‚ does not include any person who is liable to tax in
PDF 6 · en-pdf-006-line-022that State in respect only of income from sources in that State or capital situated therein.
PDF 6 · en-pdf-006-line-023(2) Where by reason of the provisions of paragraph 1 an individual is a resident of both
PDF 6 · en-pdf-006-line-024Contracting States‚ then that individual’s status shall be determined as follows: