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Union of India - Section

Section 3 in Convention between the Government of the Republic of India and the Government of the Republic of Namibia for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and capital gains

3. Where, by reason of the provisions of paragraph 1, a person 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. In case of doubt the competent authorities of the Contracting States shall settle the question by mutual agreement.

Article 5Permanent Establishment