(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, res-
idence, place of management or any other criterion of a similar
nature, and also includes that State and any political subdivi-
sion 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.
(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 permanent home available to him in both States, he shall
be deemed to be a resident only of the State with which his
personal and economic relations are closer (centre of vital
interests);
b) if the State in which he has his centre of vital interests can-
not be determined, or if he has not a permanent home avail-
able to him in either State, he shall be deemed to be a resi-
dent 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 per-
son other than an individual is a resident of both Contracting
States, then it shall be deemed to be a resident of the State in
which its place of effective management is situated.
de-syria-2010-base | BGBl. 2010 II S. 1359 | signed 2010-02-17 | published 2010-11-23 | Signed: 2010-02-17 | Gazette publication: 2010-11-23
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 Arabic as authentic; that third version is NOT present in this reader. Missing here does not mean globally unavailable. 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-syria-2010-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 2010-02-17; consent law 2010-11-18; gazette publication 2010-11-23. Edition ID year is not a signature date. Treaty entry into force: not resolved as a single source-bound field by the retained audit. Roster general application: 2011-01-01 (not a universal tax-specific rule). 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. 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. 2010 II S. 1359 | de-syria-2010-base | de-syria-2010-base | BGBl. 2010 II S. 1359 | signed 2010-02-17 | published 2010-11-23 | Signed: 2010-02-17 | Gazette publication: 2010-11-23 | Article 4 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-syria-2010-base/en/articles/article-4/
Source, edition and limits
Source edition
de-syria-2010-base | BGBl. 2010 II S. 1359 | signed 2010-02-17 | published 2010-11-23 | Signed: 2010-02-17 | Gazette publication: 2010-11-23
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 Arabic as authentic; that third version is NOT present in this reader. Missing here does not mean globally unavailable. 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-syria-2010-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 2010-02-17; consent law 2010-11-18; gazette publication 2010-11-23. Edition ID year is not a signature date. Treaty entry into force: not resolved as a single source-bound field by the retained audit. Roster general application: 2011-01-01 (not a universal tax-specific rule). 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. 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