Pablo Vera Antn.

Prctica 1 International Taxation

At the point of referring to the residence of Vladimir Sprintsjev (sportsman) we must refer to the article 4.2 of the OECD model Tax Convention, under the title Resident, we must refer to the concepts of residence, in this case we shall stand out a real property that Vladimir must own and the interests that he has in the countrie. At this time we can spot two countries; Maradonia and Pyrinea. Attending to the 4.2 article of the OECD;
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.

We conclude that the resident country is Pyrinea because it is the geographical location where he mostly stands in, a resident of Pyrenea is anyone who has his domicile or his principal abode in Pyrenea, or any person who has been staying in the country for more than 183 days. At the moment of concluding both societies (Strato and Bicluster) stand we conclude that Strato is affected to Tropico because of the resident location. Bicluster on the other hand can be considered to belong to Tropico too because of its place of effective management. We reach to this conclusion by interpretation of the article 4 OECD (special reference to 4.3) and article 5 referent to place of management of the OECD too as in permament establishment.
Article 5.1&5.2

(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