of a Contracting State and an enterprise carried on by a resident of the

other Contracting State;

h) the term “international traffic” means any transport by a ship or aircraft operated by an enterprise that has its place of effective management in a

Contracting State, except when the ship or aircraft is operated solely

between places in the other Contracting State;

i) the term “competent authority” means:

(i) in the case of Portugal: the Minister of Finance, the Director General

of [the Tax and Customs Authority] or their authorised

representative;

(ii) in the case of Ethiopia: the Minister of Finance and Economic

Development or his authorized representative;

j) the term “national” means:

(i) any individual possessing the nationality of a Contracting State; and

(ii) any legal person, partnership or association deriving its status as

such from the laws in force in a Contracting State.

2. As regards the application of the Convention at any time by a Contracting State,

any term not defined therein shall, unless the context otherwise requires, have the

meaning that it has at that time under the law of that Stateconcerning the taxes to which

the Convention applies, any meaning under the applicable tax laws of that State

prevailing over a meaning given to the term under other laws of that State.

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 effective management, place of registrationor any

other criterion of a similar nature, and also includes that State and any political or

administrative subdivisionor local authority thereof. 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.

2. 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

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