Activity provision. “The foregoing provisions shall not apply where the com- pany is engaged in substantive business operations in the Contracting State of which it is a resident and the relief from taxation claimed from the other Contracting State is with respect to income that is connected with such operations.”
Appears in 3 contracts
Samples: cdi.mecon.gob.ar, www.ciat.org, tpguidelines.com
Activity provision. “The foregoing provisions shall not apply where the com- pany is engaged in substantive business operations in the Contracting State of which it is a resident and the relief from taxation claimed from the other Contracting State is with respect to income that which is connected with such operationsoper- ations.”
Appears in 2 contracts
Samples: www.finanze.it, www.un.org