Artikel 4 Verdrag tussen het Koninkrijk der Nederlanden, ten behoeve van Curaçao, en de Republiek Suriname tot het vermijden van dubbele belasting met betrekking tot belastingen naar het inkomen en naar het vermogen en het voorkomen van het ontduiken en ontwijken van belasting

Article 4 Resident 1 For the purposes of this Convention, 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, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof as well as a recognized pension fund of that State. 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 A person, other than an individual, shall be regarded to be liable to tax: a) in Curaçao, if the person is a resident of Curaçao for the purposes of profit tax; b) in Suriname, if the person is a resident of Suriname for the purposes of income tax; provided that the income derived by that person is treated under the tax laws of that State as income of that person and not as the income of the person’s beneficiaries, members or participants. 3 Where by reason of the provisions of paragraph 1 an individual 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 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. 4 Where by reason of the provisions of paragraph 2 a person other than an individual is a resident of both Contracting States, its status shall be deemed as follows: a) it shall be resident of the Contracting State in which its place of management is situated; b) if it is not clear where its place of effective management is situated, the competent authorities of the Contracting States shall settle the question by mutual agreement.