Governmental Entity. The States of Guernsey, any political subdivision of Guernsey (which, for the avoidance of doubt, includes a state, province, county, or municipality), or any wholly owned agency or instrumentality of Guernsey or any one or more of the foregoing (each, a “Guernsey Governmental Entity”). This category is comprised of the integral parts, controlled entities, and political subdivisions of Guernsey. 1. An integral part of Guernsey means any person, organisation, agency, bureau, fund, instrumentality, or other body, however designated, that constitutes a governing authority of Guernsey. The net earnings of the governing authority must be credited to its own account or to other accounts of a Guernsey Governmental Entity, with no portion inuring to the benefit of any private person. An integral part does not include any individual who is a sovereign, official, or administrator acting in a private or personal capacity. 2. A controlled entity means an Entity that is separate in form from Guernsey or that otherwise constitutes a separate juridical entity, provided that: a) The Entity is wholly owned and controlled by one or more Guernsey Governmental Entities directly or through one or more controlled entities; b) The Entity’s net earnings are credited to its own account or to the accounts of one or more Guernsey Governmental Entities, with no portion of its income inuring to the benefit of any private person; and c) The Entity’s assets vest in one or more Guernsey Governmental Entities upon dissolution. 3. Income does not inure to the benefit of private persons if such persons are the intended beneficiaries of a governmental program, and the program activities are performed for the general public with respect to the common welfare or relate to the administration of some phase of government. Notwithstanding the foregoing, however, income is considered to inure to the benefit of private persons if the income is derived from the use of a governmental entity to conduct a commercial business, such as a commercial banking business, that provides financial services to private persons.
Appears in 5 contracts
Samples: Agreement to Improve International Tax Compliance, Agreement to Improve International Tax Compliance, Agreement to Improve International Tax Compliance
Governmental Entity. The States government of GuernseyAnguilla, any political subdivision of Guernsey Anguilla (which, for the avoidance of doubt, includes a state, province, county, or municipality), or any wholly owned agency or instrumentality of Guernsey Anguilla or any one or more of the foregoing (each, a an “Guernsey Anguillian Governmental Entity”). This category is comprised of the integral parts, controlled entities, and political subdivisions of GuernseyAnguilla.
1. An integral part of Guernsey Anguilla means any person, organisationorganization, agency, bureau, fund, instrumentality, or other body, however designated, that constitutes a governing authority of GuernseyAnguilla. The net earnings of the governing authority must be credited to its own account or to other accounts of a Guernsey Governmental EntityAnguilla, with no portion inuring to the benefit of any private person. An integral part does not include any individual who is a sovereign, official, or administrator acting in a private or personal capacity.
2. A controlled entity means an Entity that is separate in form from Guernsey Anguilla or that otherwise constitutes a separate juridical entity, provided that:
a) The Entity is wholly owned and controlled by one or more Guernsey Anguillian Governmental Entities directly or through one or more controlled entities;
b) The Entity’s net earnings are credited to its own account or to the accounts of one or more Guernsey Anguillian Governmental Entities, with no portion of its income inuring to the benefit of any private person; and
c) The Entity’s assets vest in one or more Guernsey Anguillian Governmental Entities upon dissolution.
3. Income does not inure to the benefit of private persons if such persons are the intended beneficiaries of a governmental program, and the program activities are performed for the general public with respect to the common welfare or relate to the administration of some phase of government. Notwithstanding the foregoing, however, income is considered to inure to the benefit of private persons if the income is derived from the use of a governmental entity to conduct a commercial business, such as a commercial banking business, that provides financial services to private persons.
Appears in 2 contracts
Samples: International Tax Compliance Agreement, Tax Agreement
Governmental Entity. The States government of Guernsey, any political subdivision of Guernsey (which, for the avoidance of doubt, includes a state, province, county, or municipality), or any wholly owned agency or instrumentality of Guernsey or any one or more of the foregoing (each, a “Guernsey Governmental Entity”). This category is comprised of the integral parts, controlled entities, and political subdivisions of Guernsey.
1. An integral part of Guernsey means any person, organisationorganization, agency, bureau, fund, instrumentality, or other body, however designated, that constitutes a governing authority of Guernsey. The net earnings of the governing authority must be credited to its own account or to other accounts of a Guernsey Governmental EntityGuernsey, with no portion inuring to the benefit of any private person. An integral part does not include any individual who is a sovereign, official, or administrator acting in a private or personal capacity.
2. A controlled entity means an Entity that is separate in form from Guernsey or that otherwise constitutes a separate juridical entity, provided that:
a) The Entity is wholly owned and controlled by one or more Guernsey Governmental Entities directly or through one or more controlled entities;
b) The Entity’s net earnings are credited to its own account or to the accounts of one or more Guernsey Governmental Entities, with no portion of its income inuring to the benefit of any private person; and
c) The Entity’s assets vest in one or more Guernsey Governmental Entities upon dissolution.
3. Income does not inure to the benefit of private persons if such persons are the intended beneficiaries of a governmental program, and the program activities are performed for the general public with respect to the common welfare or relate to the administration of some phase of government. Notwithstanding the foregoing, however, income is considered to inure to the benefit of private persons if the income is derived from the use of a governmental entity to conduct a commercial business, such as a commercial banking business, that provides financial services to private persons.
Appears in 2 contracts
Samples: International Tax Compliance Agreement, International Tax Compliance Agreement
Governmental Entity. The States government of GuernseyBermuda, any political subdivision of Guernsey Bermuda (which, for the avoidance of doubt, includes a state, province, county, or municipality), or any wholly owned agency or instrumentality of Guernsey Bermuda or any one or more of the foregoing (each, a “Guernsey Bermuda Governmental Entity”). This category is comprised of the integral parts, controlled entities, and political subdivisions of GuernseyBermuda.
1. An integral part of Guernsey Bermuda means any person, organisation, agency, bureau, fund, instrumentality, or other body, however designated, that constitutes a governing authority of GuernseyBermuda. The net earnings of the governing authority must be credited to its own account or to other accounts of a Guernsey Bermuda Governmental Entity, with no portion inuring to the benefit of any private person. An integral part does not include any individual who is a sovereign, official, or administrator acting in a private or personal capacity.
2. A controlled entity means an Entity that is separate in form from Guernsey Bermuda or that otherwise constitutes a separate juridical entity, provided that:
a) The Entity is wholly owned and controlled by one or more Guernsey Bermuda Governmental Entities directly or through one or more controlled entities;
b) The Entity’s net earnings are credited to its own account or to the accounts of one or more Guernsey Bermuda Governmental Entities, with no portion of its income inuring to the benefit of any private person; and
c) The Entity’s assets vest in one or more Guernsey Bermuda Governmental Entities upon dissolution.
3. Income does not inure to the benefit of private persons if such persons are the intended beneficiaries of a governmental program, and the program activities are performed for the general public with respect to the common welfare or relate to the administration of some phase of government. Notwithstanding the foregoing, however, income is considered to inure to the benefit of private persons if the income is derived from the use of a governmental entity to conduct a commercial business, such as a commercial banking business, that provides financial services to private persons.
Appears in 2 contracts
Samples: International Tax Compliance Agreement, International Tax Compliance Agreement
Governmental Entity. The States government of GuernseyAnguilla, any political subdivision of Guernsey Anguilla (which, for the avoidance of doubt, includes a state, province, county, or municipality), or any wholly owned agency or instrumentality of Guernsey Anguilla or any one or more of the foregoing (each, a “Guernsey Anguilla Governmental Entity”). This category is comprised of the integral parts, controlled entities, and political subdivisions of GuernseyAnguilla.
1. An integral part of Guernsey Anguilla means any person, organisation, agency, bureau, fund, instrumentality, or other body, however designated, that constitutes a governing authority of GuernseyAnguilla. The net earnings of the governing authority must be credited to its own account or to other accounts of a Guernsey Anguilla Governmental Entity, with no portion inuring to the benefit of any private person. An integral part does not include any individual who is a sovereign, official, or administrator acting in a private or personal capacity.
2. A controlled entity means an Entity that is separate in form from Guernsey Anguilla or that otherwise constitutes a separate juridical entity, provided that:
a) The Entity is wholly owned and controlled by one or more Guernsey Anguilla Governmental Entities directly or through one or more controlled entities;
b) The Entity’s net earnings are credited to its own account or to the accounts of one or more Guernsey Anguilla Governmental Entities, with no portion of its income inuring to the benefit of any private person; and
c) The Entity’s assets vest in one or more Guernsey Anguilla Governmental Entities upon dissolution.
3. Income does not inure to the benefit of private persons if such persons are the intended beneficiaries of a governmental program, and the program activities are performed for the general public with respect to the common welfare or relate to the administration of some phase of government. Notwithstanding the foregoing, however, income is considered to inure to the benefit of private persons if the income is derived from the use of a governmental entity to conduct a commercial business, such as a commercial banking business, that provides financial services to private persons.
Appears in 2 contracts
Samples: International Tax Compliance Agreement, Tax Compliance Agreement
Governmental Entity. The States government of GuernseyTurkmenistan, any political subdivision of Guernsey Turkmenistan (which, for the avoidance of doubt, includes a state, province, county, or municipality), or any wholly owned agency or instrumentality of Guernsey Turkmenistan or any one or more of the foregoing (each, a “Guernsey Governmental EntityEntity of Turkmenistan”). This category is comprised of the integral parts, controlled entities, and political subdivisions of GuernseyTurkmenistan.
1. An integral part of Guernsey Turkmenistan means any person, organisationorganization, agency, bureau, fund, instrumentality, or other body, however designated, that constitutes a governing authority of GuernseyTurkmenistan. The net earnings of the governing authority must be credited to its own account or to other accounts of a Guernsey Governmental EntityTurkmenistan, with no portion inuring to the benefit of any private person. An integral part does not include any individual who is a sovereign, official, or administrator acting in a private or personal capacity.
2. A controlled entity means an Entity that is separate in form from Guernsey Turkmenistan or that otherwise constitutes a separate juridical entity, provided that:
a) The Entity is wholly owned and controlled by one or more Guernsey Governmental Entities of Turkmenistan directly or through one or more controlled entities;
b) The Entity’s net earnings are credited to its own account or to the accounts of one or more Guernsey Governmental EntitiesEntities of Turkmenistan, with no portion of its income inuring to the benefit of any private person; and
c) The Entity’s assets vest in one or more Guernsey Governmental Entities of Turkmenistan upon dissolution.
3. Income does not inure to the benefit of private persons if such persons are the intended beneficiaries of a governmental program, and the program activities are performed for the general public with respect to the common welfare or relate to the administration of some phase of government. Notwithstanding the foregoing, however, income is considered to inure to the benefit of private persons if the income is derived from the use of a governmental entity to conduct a commercial business, such as a commercial banking business, that provides financial services to private persons.
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