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.

3. Where by reason of the provisions of paragraph 1 a person other than an indi-vidual is a resident of both Contracting States, the competent authorities of the Contract-ing States shall endeavour to determine by mutual agreement the Contracting State of which such person shall be deemed to be a resident for the purposes of the Convention, having regard to its place of effective management, the place where it is incorporated or otherwise constituted and any other relevant factors. In the absence of such agreement, such person shall not be entitled to any relief or exemption from tax provided by this Convention, except for Articles 24 and 25.

ARTICLE 5

PERMANENT ESTABLISHMENT 1. For the purposes of this Convention, the term “permanent establishment” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term “permanent establishment” includes especially:

a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop; and

f) a mine, an oil or gas well, a quarry or any other place relating to the exploration for or the exploitation of natural resources.

3. The term “permanent establishment” shall also include:

a) a building site, a construction, assembly or installation project or supervi-sory activities in connection therewith, but only if such site, project or ac-tivities last more than 183 days within any twelve month period;

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