Entitlement to Benefits. Notwithstanding the other provisions of this Convention, a benefit under the Convention shall not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of the Convention.
Appears in 8 contracts
Samples: www.mof.go.jp, www.ilajapan.org, www.mof.go.jp
Entitlement to Benefits. 1. Notwithstanding the other provisions of this Convention, a benefit under the this Convention shall not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of the this Convention.
Appears in 4 contracts
Samples: opac.oireachtas.ie, www.revenue.ie, ch-businessdesign.com
Entitlement to Benefits. Notwithstanding the other provisions of this Convention, a benefit under the this Convention shall not be granted in respect of an item of income or capital if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of the this Convention.
Appears in 4 contracts
Samples: www.iras.gov.sg, www.iras.gov.sg, www.iras.gov.sg
Entitlement to Benefits. Notwithstanding the other provisions of this Convention, a benefit under the this Convention shall not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of the this Convention.
Appears in 3 contracts
Samples: archiv.llv.li, assets.gov.ie, www.revenue.ie
Entitlement to Benefits. 1. Notwithstanding the other provisions of this Convention, a benefit under the this Convention shall not be granted in respect of an item of income income, profits or gains if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of the this Convention.
Appears in 1 contract
Samples: treasury.gov.au
Entitlement to Benefits. 1. Notwithstanding the other provisions of this Convention, a benefit under the this Convention shall not be granted in respect of an item of income incarne or capital if it is reasonable to conclude, having regard to all ail relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object abject and purpose of the relevant provisions of the this Convention.
Appears in 1 contract
Samples: impotsdirects.public.lu