4. Without prejudice to paragraphs 1 and 2 below, a person, other than a representative having an independent legal status to whom paragraph 5 applies, applies in a Contracting State to the company of an enterprise of the other Contracting State, that enterprise shall be deemed to be a permanent establishment in the first-mentioned State if — a. He shall be deemed to be established in the Contracting State in which he has permanent accommodation. If he has a permanent domicile in both States Parties, he shall be deemed to be resident in the Contracting State with which his personal and economic relations are closest (centre of vital interests); Lal Shanker Ghimire, Secretary (Revenue) of the Nepalese Ministry of Finance and Mosharraf Hossain Bhuiyan, Chief Secretary (Department of Internal Resources) at the Ministry of Finance of Bangladesh, signed the agreement on behalf of their respective governments in Kathmandu. 7. To the extent that it was customary in a State Party to determine the profits attributable to a permanent establishment on the basis of an apportionment of the total profits of the enterprise among its various parts, paragraph 2 shall not prevent that State Party from taxing taxable profits by an ordinary apportionment; However, the method of allocation chosen must be such that the result conforms to the principles set out in this Article. 2. If a natural person resides in both States Parties under the provisions of paragraph 1 of this Article, his or her case shall be determined according to the following rules: “The agreement reached today is for the purpose of settling the tax claims of the Government of Nepal and the Government of Bangladesh,” the Ministry of Finance of Nepal said in a statement. .