(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 management or any other criterion of a similar
nature, and also includes that State, a Land and any political
subdivision or local authority thereof. 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 com-
pany is a resident of both Contracting States, then it shall be
deemed to be a resident of the State in which its place of effec-
tive management is situated.
de-costa-rica-2014-base | BGBl. 2014 II S. 917 | signed 2014-02-13 | published 2014-11-26 | Signed: 2014-02-13 | Gazette publication: 2014-11-26
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, multilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
Native German and English source transcriptions only. The signing clause names German, Spanish and English as authentic, with English prevailing on divergent interpretation of German/Spanish. Spanish is NOT printed as treaty text in this retained PDF and is NOT supplied here; no translation or global unavailability claim. Original signature 2014-02-13; gazette publication 2014-11-26; not current consolidated law. No qualified human wording review, legal review, current-law or publication approval. 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-costa-rica-2014-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 as current law. Signed 2014-02-13; consent law 2014-11-20; gazette publication 2014-11-26. Edition ID year is not a signature date. Treaty entry into force: 2016-08-10. Roster general application: 2017-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 10. August 2016. Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. 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
Printed signature protocol retained separately and not merged into articles. Roster future-instrument/negotiation entry (NOT proof of operative amendment): Costa Rica R-P V. P = Paraphierung (initialled), NOT signature; U = signed, ratification pending; V = negotiation. R-P protocol/R-A replacement. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated 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. 2014 II S. 917 | de-costa-rica-2014-base | de-costa-rica-2014-base | BGBl. 2014 II S. 917 | signed 2014-02-13 | published 2014-11-26 | Signed: 2014-02-13 | Gazette publication: 2014-11-26 | Article 4 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-costa-rica-2014-base/en/articles/article-4/
Source, edition and limits
Source edition
de-costa-rica-2014-base | BGBl. 2014 II S. 917 | signed 2014-02-13 | published 2014-11-26 | Signed: 2014-02-13 | Gazette publication: 2014-11-26
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, multilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
Native German and English source transcriptions only. The signing clause names German, Spanish and English as authentic, with English prevailing on divergent interpretation of German/Spanish. Spanish is NOT printed as treaty text in this retained PDF and is NOT supplied here; no translation or global unavailability claim. Original signature 2014-02-13; gazette publication 2014-11-26; not current consolidated law. No qualified human wording review, legal review, current-law or publication approval. 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-costa-rica-2014-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 as current law. Signed 2014-02-13; consent law 2014-11-20; gazette publication 2014-11-26. Edition ID year is not a signature date. Treaty entry into force: 2016-08-10. Roster general application: 2017-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 10. August 2016. Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. 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
Printed signature protocol retained separately and not merged into articles. Roster future-instrument/negotiation entry (NOT proof of operative amendment): Costa Rica R-P V. P = Paraphierung (initialled), NOT signature; U = signed, ratification pending; V = negotiation. R-P protocol/R-A replacement. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated 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