Encyclopedia
Person with a permanent place of residence
A resident — means any person who, under the law of this State, is subject to taxation in it on the basis of his residence, habitual abode, place of management or any other similar criterion1.
A resident — means any person who, under the law of the Contracting State, is subject to taxation in it on the basis of his residence, habitual abode, place of registration or any other similar criterion. However, this term does not include a person who is subject to taxation in the Contracting State only with respect to income derived from sources within that State or with respect to property situated therein2.
Agreement between the Government of the Russian Federation and the Government of Canada on the Avoidance of Double Taxation and the Prevention of Tax Evasion with Respect to Income and Property Taxes, as amended on 1997-06-23, Article 4. ↩
Agreement between the Government of the Russian Federation and the Government of the Slovak Republic on the Avoidance of Double Taxation of Income and Property, as amended on 1997-06-16, Article 4. ↩