1. For the purposes of this Agreement, 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, resi-
dence, place of incorporation, place of management or any other
criterion of a similar nature, and also includes that State, any of
its “Länder” and any of their political subdivisions or local au-
thorities. This term, however, does not include any person who
is liable to tax in that State in respect only of income from
sources in that State 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 State in which
he has a permanent home available to him; if he has a per-
manent home available to him in both States, he shall be
deemed to be a resident only of the State with which his per-
sonal and economic relations are closer (centre of vital inter-
ests);
b) if the 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 State, he shall be deemed to be a resident
only of the State in which he has an habitual abode;
c) if he has an habitual abode in both States or in neither of
them, he shall be deemed to be a resident only of the State
of which he is a national;
d) if he is a national of both 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 person
other than an individual is a resident of both Contracting States,
then the competent authorities of the Contracting States shall
endeavor to determine by mutual agreement the Contracting
State of which that person shall be deemed to be a resident for
the purposes of this Agreement. In the absence of a mutual
agreement by the competent authorities of the Contracting
States the person shall not be considered a resident of either
Contracting State for the purposes of claiming any benefits pro-
vided by the Agreement.
de-armenia-2017-base | BGBl. 2017 II S. 1077 | Signed: 2016-06-29 | Gazette publication: 2017-07-27
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
This source supplies German and English versions. The signing clause also identifies Armenian as authentic; that third version is NOT present in this reader. 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-armenia-2017-base/. PDF page links identify pages, not verified paragraph correspondence.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
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.
Protocols and later instruments
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.
Text language and status
en · authentic-language-transcription · machine-transcription
BGBl. 2017 II S. 1077 | de-armenia-2017-base | de-armenia-2017-base | BGBl. 2017 II S. 1077 | Signed: 2016-06-29 | Gazette publication: 2017-07-27 | Article 4 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-armenia-2017-base/en/articles/article-4/
Source, edition and limits
Source edition
de-armenia-2017-base | BGBl. 2017 II S. 1077 | Signed: 2016-06-29 | Gazette publication: 2017-07-27
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
This source supplies German and English versions. The signing clause also identifies Armenian as authentic; that third version is NOT present in this reader. 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-armenia-2017-base/. PDF page links identify pages, not verified paragraph correspondence.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
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.
Protocols and later instruments
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.
Text language and status
en · authentic-language-transcription · machine-transcription