Common use of General Scope Clause in Contracts

General Scope. 1. This Convention shall apply to persons who are residents of one or both of the Contracting States, except as otherwise provided in the Convention. 2. The Convention shall not restrict in any manner any exclusion, exemption, deduction, credit, or other allowance now or hereafter accorded: a) by the laws of either Contracting State; or b) by any other agreement between the Contracting States. 3. Notwithstanding the provisions of subparagraph 2 b): a) the provisions of Article 26 (Mutual Agreement Procedure) of this Convention exclusively shall apply to any dispute concerning whether a measure is within the scope of this Convention, and the procedures under this Convention exclusively shall apply to that dispute; and b) unless the competent authorities determine that a taxation measure is not within the scope of this Convention, the nondiscrimination obligations of this Convention exclusively shall apply with respect to that measure, except for such national treatment or most- favored-nation obligations as may apply to trade in goods under the General Agreement on Tariffs and Trade. No national treatment or most-favored-nation obligation under any other agreement shall apply with respect to that measure. c) For the purpose of this paragraph, a "measure" is a law,regulation,rule, procedure, decision, administrative action, or any similar provision or action. 4. Notwithstanding any provision of the Convention except paragraph 5 of this Article, a Contracting State may tax its residents (as determined under Article 4 (Resident)), and by reason of citizenship may tax its citizens, as if the Convention had not come into effect. For this purpose, the term "citizen" shall include a former citizen or long-term resident whose loss of such status had as one of its principal purposes the avoidance of tax, but only for a period of 10 years following such loss. 5. The provisions of paragraph 4 shall not affect: a) the benefits conferred by a Contracting State under paragraph 2 of Article 9 (Associated Enter- prises), under paragraphs 2 and 5 of Article 18 (Pensions, Social Security, Annuities, Alimony, and Child Support), and under Articles 24 (Relief from Double Taxation), 25 (Nondiscrimination), and 26 (Mutual Agreement Procedure); and b) the benefits conferred by a Contracting State under Articles 19 (Government Service), 20 (Students, Trainees and Researchers), and 28 (Members of Diplomatic Missions and Consular Posts), upon individuals who are neither citizens of, nor have been admitted for permanent residence in, that State.

General Scope. 1. This Convention shall apply to persons who are residents of one or both of the Contracting States, except as otherwise provided in the Convention. 2. The Convention shall not restrict in any manner any exclusion, exemption, deduction, credit, or other allowance now or hereafter accorded: a) by the laws of either Contracting State; or b) by any other agreement between the Contracting States. 3. Notwithstanding the provisions of subparagraph 2 b): a) the provisions of Article 26 (Mutual Agreement Procedure) of this Convention exclusively shall apply to any dispute concerning whether a measure is within the scope of this Convention, and the procedures under this Convention exclusively shall apply to that dispute; and b) unless the competent authorities determine that a taxation measure is not within the scope of this Convention, the nondiscrimination obligations of this Convention exclusively shall apply with respect to that measure, except for such national treatment or most- favored-nation obligations as may apply to trade in goods under the General Agreement on Tariffs and Trade. No national treatment or most-favored-nation obligation under any other agreement shall apply with respect to that measure. c) For the purpose of this paragraph, a "measure" is a law,, regulation,, rule, procedure, decision, administrative action, or any similar provision or action. 4. Notwithstanding any provision of the Convention except paragraph 5 of this Article, a Contracting State may tax its residents (as determined under Article 4 (Resident)), and by reason of citizenship may tax its citizens, as if the Convention had not come into effect. For this purpose, the term "citizen" shall include a former citizen or long-term resident whose loss of such status had as one of its principal purposes the avoidance of tax, but only for a period of 10 years following such loss. 5. The provisions of paragraph 4 shall not affect: a) the benefits conferred by a Contracting State under paragraph 2 of Article 9 (Associated Enter- prisesEnterprises), under paragraphs 2 and 5 of Article 18 (Pensions, Social Security, Annuities, Alimony, and Child Support), and under Articles 24 (Relief from Double Taxation), 25 (Nondiscrimination), ) and 26 (Mutual Agreement Procedure); and b) the benefits conferred by a Contracting State under Articles 19 (Government Service), 20 (Students, Trainees and Researchers), and 28 (Members of Diplomatic Missions and Consular Posts), upon individuals who are neither citizens of, nor have been admitted for permanent residence in, that State.

General Scope. 1. This Except as specifically provided herein, this Convention shall apply is applicable only to persons who are residents of one or both of the Contracting States, except as otherwise provided in the Convention. 2. The This Convention shall not restrict in any manner any exclusion, exemption, deduction, credit, or other allowance benefit now or hereafter accorded: a) by the laws of either Contracting State; or b) by any other agreement between the Contracting States. 3. a) Notwithstanding the provisions of subparagraph sub-paragraph b) of paragraph 2 b):of this Article: a(i) any question arising as to the interpretation or application of this Convention and, in particular, whether a taxation measure is within the scope of this Convention, shall be determined exclusively in accordance with the provisions of Article 26 (Mutual Agreement Procedure) of this Convention exclusively shall apply to any dispute concerning whether a measure is within the scope of this Convention, and the procedures under this Convention exclusively shall apply to that dispute; and b(ii) the provisions of Article II and Article XVII of the General Agreement on Trade in Services shall not apply to a taxation measure unless the competent authorities determine agree that a taxation the measure is not within the scope of Article 25 (Non-discrimination) of this Convention, the nondiscrimination obligations of this Convention exclusively shall apply with respect to that measure, except for such national treatment or most- favored-nation obligations as may apply to trade in goods under the General Agreement on Tariffs and Trade. No national treatment or most-favored-nation obligation under any other agreement shall apply with respect to that measure. cb) For the purpose purposes of this paragraph, a "“measure" ” is a law,, regulation,, rule, procedure, decision, administrative action, or any similar provision or action. 4. Notwithstanding any provision of the this Convention except paragraph 5 of this Article, a Contracting State may tax its residents (as determined under Article 4 (ResidentResidence)), and by reason of citizenship may tax its citizens, as if the this Convention had not come into effect. For this purpose, the term "citizen" shall include a former citizen or long-term resident whose loss of such status had as one of its principal purposes the avoidance of tax, but only for a period of 10 years following such loss. 5. The provisions of paragraph 4 of this Article shall not affect: a) the benefits conferred by a Contracting State under paragraph 2 of Article 9 (Associated Enter- prisesEnterprises), under sub-paragraph b) of paragraph 1 and paragraphs 2 3 and 5 of Article 18 17 (Pensions, Social Security, Annuities, Alimony, and Child Support), paragraph 1 of Article 18 (Pension Schemes) and under Articles 24 (Relief from From Double Taxation), 25 (NondiscriminationNon-discrimination), and 26 (Mutual Agreement Procedure)) of this Convention; and b) the benefits conferred by a Contracting State under paragraph 2 of Article 18 (Pension Schemes) and Articles 19 (Government Service), 20 (Students, Trainees and Researchers), and 28 (Members of Diplomatic Missions Agents and Consular Posts)Officers) of this Convention, upon individuals who are neither citizens of, nor have been admitted for permanent residence in, that State. 6. A former citizen or long-term resident whose loss of citizenship or long-term resident status had as one of its principal purposes the avoidance of tax (as defined under the laws of the Contracting State of which the person was a citizen or long-term resident) shall be treated for the purposes of paragraph 4 of this Article as a citizen of that Contracting State but only for a period of 10 years following the loss of such status. This paragraph shall apply only in respect of income from sources within that Contracting State (including income deemed under the domestic law of that State to arise from such sources). Paragraph 4 of this Article shall not apply in the case of any former citizen or long-term resident of a Contracting State who ceased to be a citizen or long-term resident of that State at any time before February 6th, 1995. 7. Where under any provision of this Convention income or gains arising in one of the Contracting States are relieved from tax in that Contracting State and, under the law in force in the other Contracting State, a person, in respect of the said income or gains, is subject to tax by reference to the amount thereof which is remitted to or received in that other Contracting State and not by reference to the full amount thereof, then the relief to be allowed under this Convention in the first-mentioned Contracting State shall apply only to so much of the income or gains as is taxed in the other Contracting State. 8. An item of income, profit or gain derived through a person that is fiscally transparent under the laws of either Contracting State shall be considered to be derived by a resident of a Contracting State to the extent that the item is treated for the purposes of the taxation law of such Contracting State as the income, profit or gain of a resident.

General Scope. 1. This Convention shall apply to persons who are residents of one or both of the Contracting States, except as otherwise provided in the Convention. 2. The Convention shall not restrict in any manner any exclusion, exemption, deduction, credit, or other allowance now or hereafter accorded: a) by the laws of either Contracting State; or b) by any other agreement between the Contracting States. 3. Notwithstanding the provisions of subparagraph 2 b): a) the provisions of Article 26 (Mutual Agreement Procedure) of this Convention exclusively shall apply to any dispute concerning whether a measure is within the scope of this Convention, and the procedures under this Convention exclusively shall apply to that dispute; and b) unless the competent authorities determine that a taxation measure is not within the scope of this Convention, the nondiscrimination obligations of this Convention exclusively shall apply with respect to that measure, except for such national treatment or most- most-favored-nation obligations as may apply to trade in goods under the General Agreement on Tariffs and Trade. No national treatment or most-favored-favored- nation obligation under any other agreement shall apply with respect to that measure. c) For the purpose of this paragraph, a "measure" is a law,, regulation,, rule, procedure, decision, administrative action, or any similar provision or action. 4. Notwithstanding any provision of the Convention except paragraph 5 of this Article, a Contracting State may tax its residents (as determined under Article 4 (Resident)), and by reason of citizenship may tax its citizens, as if the Convention had not come into effect. For this purpose, the term "citizen" shall include a former citizen or long-term resident whose loss of such status had as one of its principal purposes the avoidance of tax, but only for a period of 10 years following such loss. 5. The provisions of paragraph 4 shall not affect: a) the benefits conferred by a Contracting State under paragraph 2 of Article 9 (Associated Enter- prisesEnterprises), under paragraphs 2 and 5 of Article 18 (Pensions, Social Security, Annuities, Alimony, and Child Support), and under Articles 24 (Relief from Double Taxation), 25 (Nondiscrimination), ) and 26 (Mutual Agreement Procedure); and b) the benefits conferred by a Contracting State under Articles 19 (Government Service), 20 (Students, Trainees and Researchers), and 28 (Members of Diplomatic Missions and Consular Posts), upon individuals who are neither citizens of, nor have been admitted for permanent residence in, that State.

General Scope. 1. This Convention shall apply to persons who are residents [*9] of one or both of the Contracting States, except as otherwise provided in the Convention. 2. The Convention shall not restrict in any manner any exclusion, exemption, deduction, credit, or other allowance now or hereafter accorded: a) by the laws of either Contracting State; or b) by any other agreement between the Contracting States. 3. Notwithstanding the provisions of subparagraph 2 b): a) the provisions of Article 26 (Mutual Agreement Procedure) of this Convention exclusively shall apply to any dispute concerning whether a measure is within the scope of this Convention, and the procedures under this Convention exclusively shall apply to that dispute; and b) unless the competent authorities determine that a taxation measure is not within the scope of this Convention, the nondiscrimination obligations of this Convention exclusively shall apply with respect to that measure, except for such national treatment or most- most-favored-nation obligations as may apply to trade in goods under the General Agreement on Tariffs and Trade. No national treatment or most-favored-nation obligation under any other agreement shall apply with respect to that measure. c) For the purpose of this paragraph, [*10] a "measure" is a law,, regulation,, rule, procedure, decision, administrative action, or any similar provision or action. 4. Notwithstanding any provision of the Convention except paragraph 5 of this Article, a Contracting State may tax its residents (as determined under Article 4 (Resident)), and by reason of citizenship may tax its citizens, as if the Convention had not come into effect. For this purpose, the term "citizen" shall include a former citizen or long-term resident whose loss of such status had as one of its principal purposes the avoidance of tax, but only for a period of 10 years following such loss. 5. The provisions of paragraph 4 shall not affect: a) the benefits conferred by a Contracting State under paragraph 2 of Article 9 (Associated Enter- prisesEnterprises), under paragraphs 2 and 5 of Article 18 (Pensions, Social Security, Annuities, AlimonyXxxxxxx, and Child Support), and under Articles 24 (Relief from Double Taxation), 25 (Nondiscrimination), and 26 (Mutual Agreement Procedure); andand‌‌‌‌‌‌‌‌‌‌‌‌ b) the benefits conferred by a Contracting State under Articles 19 (Government Service), 20 (Students, Trainees and Researchers), and 28 (Members of Diplomatic Missions and Consular Posts), upon [*11] individuals who are neither citizens of, nor have been admitted for permanent residence in, that State.

General Scope. 1. ) This Convention shall apply only to persons who are residents of one or both of the Contracting States, except as otherwise provided in the Convention. 2. ) The Convention shall not restrict in any manner any exclusion, exemption, deduction, credit, credit or other allowance or benefit now or hereafter accorded: a) by the laws of either Contracting State; or b) by any other agreement between the Contracting States. 3. ) Notwithstanding the provisions of subparagraph 2 b): a) the provisions of Article 26 25 (Mutual Agreement Procedure) of this Convention exclusively shall apply to any dispute concerning whether a measure is within the scope of this Convention, and the procedures under this Convention exclusively shall apply to that dispute; and b) unless the competent authorities determine that a taxation measure is not within the scope of this Convention, the nondiscrimination obligations of this Convention exclusively shall apply with respect to that measure, except for such national treatment or most- most-favored-nation obligations as may apply to trade in goods under the General Agreement on Tariffs and Trade. No national treatment or most-favored-nation obligation under any other agreement shall apply with respect to that measure. c) For the purpose purposes of this paragraph, a "“measure" “ is a law,, regulation,, rule, procedure, decision, administrative action, or any similar provision or action. 4. ) Notwithstanding any provision of the Convention except paragraph 5 of this Article, a Contracting State may tax its residents (as determined under Article 4 (ResidentResidence)), and by reason of citizenship may tax its citizens, as if the Convention had not come into effect. For this purpose, the term "“citizen" “ shall include a former citizen or long-term resident whose loss of such status had as one of its principal purposes the avoidance of taxtax (as defined under the laws of the Contracting State of which the person was a citizen or long-term resident), but only for a period of 10 years following such loss. 5. ) The provisions of paragraph 4 shall not affect: a) the benefits conferred by a Contracting State under paragraph 2 of Article 9 (Associated Enter- prisesEnterprises), under paragraphs 2 and 5 of Article 18 (Pensions, Social Security, Annuities, AlimonyXxxxxxx, and Child Support), and under Articles 24 23 (Relief from From Double Taxation), 25 24 (NondiscriminationNon-Discrimination), and 26 25 (Mutual Agreement Procedure); and b) the benefits conferred by a Contracting State under Articles 19 (Government Service), 20 (Students, Trainees Trainees, Professors and Researchers), and 28 27 (Members of Diplomatic Missions Agents and Consular PostsOfficers), upon individuals who are neither citizens of, nor have been admitted for permanent residence in, that State.

General Scope. 1. This Convention shall apply to persons who are residents of one or both of the Contracting States, except as otherwise provided in the Convention. 2. The Convention shall not restrict in any manner any exclusion, exemption, deduction, credit, or other allowance now or hereafter accorded: a) by the laws of either Contracting State; or b) by any other agreement between the Contracting States. 3. Notwithstanding the provisions of subparagraph 2 b): a) the provisions of Article 26 25 (*) (Mutual Agreement Procedure) of this Convention exclusively shall apply to any dispute concerning whether a measure is within the scope of this Convention, and the procedures under this Convention exclusively shall apply to that dispute; and b) unless the competent authorities determine that a taxation measure is not within the scope of this Convention, the nondiscrimination obligations of this Convention exclusively shall apply with respect to that measure, except for such national treatment or most- most-favored-nation obligations as may apply to trade in goods under the General Agreement on Tariffs and Trade. No national treatment or most-favored-nation obligation under any other agreement shall apply with respect to that measure. c) For the purpose of this paragraph, a "measure" is a law,, regulation,, rule, procedure, decision, administrative action, or any similar provision or action. 4. Notwithstanding any provision of the Convention except paragraph 5 of this Article, a Contracting State may tax its residents (as determined under Article 4 (Resident)), and by reason of citizenship may tax its citizens, as if the Convention had not come into effect. For this purpose, the term "citizen" shall include a former citizen or long-term resident whose loss of such status had as one of its principal purposes the avoidance of tax, but only for a period of 10 years following such loss. 5. The provisions of paragraph 4 shall not affect: a) the benefits conferred by a Contracting State under paragraph 2 of Article 9 (Associated Enter- prisesEnterprises), under paragraphs 2 and 5 of Article 18 (Pensions, Social Security, Annuities, Alimony, and Child Support), and under Articles 24 23 (Relief from Double Taxation), 25 24 (Nondiscrimination), and 26 25 (Mutual Agreement Procedure); and b) the benefits conferred by a Contracting State under Articles 19 (Government Service), 20 (Students, Trainees and Researchers), and 28 27 (Members of Diplomatic Missions and Consular Posts), upon individuals who are neither citizens of, nor have been admitted for permanent residence in, that State.

General Scope. 1. This Convention shall apply to persons who are residents of one or both of the Contracting States, except as otherwise provided in the Convention. 2. The Convention shall not restrict in any manner any exclusion, exemption, deduction, credit, or other allowance now or hereafter accorded: a) by the laws of either Contracting State; or b) by any other agreement between the Contracting States. 3. Notwithstanding the provisions of subparagraph 2 b): a) the provisions of Article 26 (Mutual Agreement Procedure) of this Convention exclusively shall apply to any dispute concerning whether a measure is within the scope of this Convention, and the procedures under this Convention exclusively shall apply to that dispute; and b) unless the competent authorities determine that a taxation measure is not within the scope of this Convention, the nondiscrimination obligations of this Convention exclusively shall apply with respect to that measure, except for such national treatment or most- favored-nation obligations as may apply to trade in goods under the General Agreement on Tariffs and Trade. No national treatment or most-favored-nation obligation under any other agreement shall apply with respect to that measure. c) For the purpose of this paragraph, a "measure" is a law,, regulation,, rule, procedure, decision, administrative action, or any similar provision or action. 4. Notwithstanding any provision of the Convention except paragraph 5 of this Article, a Contracting State may tax its residents (as determined under Article 4 (Resident)), and by reason of citizenship may tax its citizens, as if the Convention had not come into effect. For this purpose, the term "citizen" shall include a former citizen or long-term resident whose loss of such status had as one of its principal purposes the avoidance of tax, but only for a period of 10 years following such loss. 5. The provisions of paragraph 4 shall not affect: a) the benefits conferred by a Contracting State under paragraph 2 of Article 9 (Associated Enter- prisesEnterprises), under paragraphs 2 and 5 of Article 18 (Pensions, Social Security, Annuities, Alimony, and Child Support), and under Articles 24 23 (Relief from Double Taxation), 25 24 (Nondiscrimination), and 26 25 (Mutual Agreement Procedure); and b) the benefits conferred by a Contracting State under Articles 19 (Government Service), 20 (Students, Trainees and Researchers), and 28 27 (Members of Diplomatic Missions and Consular Posts), upon individuals who are neither citizens of, nor have been admitted for permanent residence in, that State.

General Scope. 1. This Convention shall apply to persons who are residents of one or both of the Contracting States, except as otherwise provided in the Convention. 2. The This Convention shall not restrict in any manner any exclusion, exemption, deductionde- duction, credit, or other allowance now or hereafter accorded: a) by By the laws of either Contracting State; or b) by By any other agreement between the Contracting States. 3. Notwithstanding the provisions of subparagraph 2 b): a) the The provisions of Article 26 (Mutual Agreement Procedure) of this Convention Con- vention exclusively shall apply to any dispute concerning whether a measure meas- ure is within the scope of this Convention, and the procedures under this Convention exclusively shall apply to that dispute; and b) unless Unless the competent authorities determine that a taxation measure is not within the scope of this Convention, the nondiscrimination non-discrimination obligations of this Convention exclusively shall apply with respect to that measure, except for such national treatment or most- favored-most favored nation obligations as may apply to trade in goods under the General Agreement on Tariffs and Trade. No national treatment or most-favored-most favored nation obligation under any other agreement shall apply with respect to that measure. c) For the purpose of this paragraph, a "measure" is a law,, regulation,, rule, procedure, decision, administrative action, or any similar provision or actionac- tion. 4. Notwithstanding any provision of the Convention except paragraph 5 of this ArticleAr- ticle, a Contracting State may tax its residents (as determined under Article 4 (ResidentResi- dence)), and by reason of citizenship may tax its citizens, as if the Convention had not come into effect. For this purpose, the term "citizen" shall include a former citizen or long-term resident whose loss of such status had as one of its principal purposes the avoidance of tax, but only for a period of 10 years following such loss. 5. The provisions of paragraph 4 shall not affect: a) the The benefits conferred by a Contracting State under paragraph 2 of Article 9 (Associated Enter- prises), under paragraphs 2 and 5 of Article 18 (Pensions, Social Security, Annuities, Alimony, and Child SupportEnterprises), and under Articles 24 (Relief from Double Taxation), 25 (NondiscriminationNon-discrimination), and 26 (Mutual Agreement Procedureprocedure); and b) the The benefits conferred by a Contracting State under Articles 19 20 (Government Govern- ment Service), 20 21 (Students, Trainees Trainees, Teachers and Researchers), and 28 (Members of Diplomatic Missions Agents and Consular PostsOfficers), upon individuals who are neither nei- ther citizens of, nor have been admitted for permanent residence immigrant status in, that State.