29 | II Série A - Número: 095S1 | 11 de Janeiro de 2012

2. For the purposes of paragraph 1 of this Article, the tem "resident of a Con- tracting state" also includes that state and any political or administrative subdivision, local government, local authority, or the Central Bank thereof; and any governrnental institution, including the Abu Dhabi Investment Authority and the Intemational Petro- leurn Investment Company, created in that State under public law which is wholly owned by that State, or any political or administrative subdivision, local government or local authority thereof.
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 deter- mined, 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 au- thorities of the Contracting States shall settle the question by mutual agreement.
4. Where by reason of the provisions of paragraph 1 a person other than an indi- vidual is a resident of both Contracting States, then it shall be deemed to be a resident only of the State in which its place of effective management is situated.- ARTICLE 5 PERMANENT ESTABLISHMENT 1. For the purposes of this Convention, the tem "permanent establishrnent" means a fixed place of business through which the business of an enterprise is wholly or partly carried on.
2. The tem "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory;