Common use of LIMITATION OF RELIEF Clause in Contracts

LIMITATION OF RELIEF. (1) Where under any provision of this Agreement any income or gains are relieved from tax in a Contracting State and, under the law in force in the other Contracting State a person, in respect of that income or those gains, is subject to tax by reference to the amount thereof which is remitted to or received in that other State and not by reference to the full amount thereof, then the relief to be allowed under this Agreement in the first-mentioned State shall apply only to so much of the income or gains as is taxed in the other State. (2) Notwithstanding the provisions of any other Article of this Agreement, a resident of a Contracting State who, as a consequence of domestic law concerning incentives to promote foreign investment, is not subject to tax or is subject to tax at a reduced rate in that State on income or on capital gains, shall not receive the benefit of any reduction in or exemption from tax provided for in this Agreement by the other Contracting State if the main purpose or one of the main purposes of such resident or a person connected with such resident was to obtain the benefits of this Agreement.

LIMITATION OF RELIEF. (1) Where under any provision of this Agreement Convention any income or gains are is relieved from tax in a Contracting State and, under the law in force in the other Contracting State a person, in respect of that income or those gainsincome, 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 Agreement 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. (2) Notwithstanding the provisions of any other Article of this AgreementConvention, a resident of a Contracting State who, as a consequence of domestic law concerning incentives to promote foreign investment, is not subject to tax or is subject to tax at a reduced rate in that Contracting State on income or on capital gains, shall not receive the benefit of any reduction in or exemption from tax provided for in this Agreement Convention by the other Contracting State if the main purpose or one of the main purposes of such resident or a person connected with such resident was to obtain the benefits of this AgreementConvention.

LIMITATION OF RELIEF. (1) 1 Where under any provision of this Agreement any income or gains are relieved from tax in a Contracting State and, under the law in force in the other Contracting State a person, in respect of that income or those gains, is subject to tax by reference to the amount thereof which is remitted to or received in that other State and not by reference to the full amount thereof, then the relief to be allowed under this Agreement in the first-mentioned State shall apply only to so much of the income or gains as is taxed in the other State. (2) . 2 Notwithstanding the provisions of any other Article of this Agreement, a resident of a Contracting State who, as a consequence of domestic law concerning incentives to promote foreign investment, is not subject to tax or is subject to tax at a reduced rate in that State on income or on capital gains, shall not receive the benefit of any reduction in or exemption from tax provided for in this Agreement by the other Contracting State if the main purpose or one of the main purposes of such resident or a person connected with such resident was to obtain the benefits of this Agreement.. Article 25

LIMITATION OF RELIEF. (1) . Where under any provision of this Agreement Convention any income or gains are is relieved from tax in a Contracting State and, under the law in force in the other Contracting State a person, in respect of that income or those gainsincome, 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 Agreement 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. (2) . Notwithstanding the provisions of any other Article of this AgreementConvention, a resident of a Contracting State who, as a consequence of domestic law concerning incentives to promote foreign investment, is not subject to tax or is subject to tax at a reduced rate in that Contracting State on income or on capital gains, shall not receive the benefit of any reduction in or exemption from tax provided for in this Agreement Convention by the other Contracting State if the main purpose or one of the main purposes of such resident or a person connected with such resident was to obtain the benefits of this AgreementConvention.