A resident of a Contracting. State shall nevertheless be granted the benefits of the Agreement if the Competent Authority of the other Contracting State determines that the said resident actively carries out business in the other State and that the establishment or acquisition or maintenance of such person and the conduct of its operations did not have as one of its principal purposes the obtaining of benefits under the Agreement.
Appears in 4 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
