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When the above rule not be applicable, or is not sufficient to give the address of the company to one of the Contracting States, the company is deemed to be domiciled in the place where its effective management is to be found or, alternatively, at the site is found to be the main focus of their activity.
When however the rules set forth in this paragraph d) is not possible to determine the residence, the competent authorities of the Contracting States shall settle the question by mutual agreement.

• The term “source of production” in a Contracting State “not interested in the nationality, domicile or residence of the owner or the parties involved in the operations or the place of conclusion of contracts, assets or rights located, placed or economically used in that State, carried out in its territory of any act or activity and the events within its boundaries capable of producing profits, income or profits.
• The term “business activities” refers to activities undertaken by companies of either Contracting State.
• The term “undertaking” means an organization constituted by one or more persons engaged in gainful activity or speculation.
• The terms “enterprise of a Contracting State” and “enterprise of the other Contracting State” mean an enterprise resident in either Contracting State.
• The term “royalty” refers to any benefits or compensation in money or kind paid for the use or the privilege of using copyrights, patents, industrial designs, procedures or exclusive formulas, trademarks and other intangible assets of a similar nature .

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