SILENT PARTNERSHIP. Notwithstanding any other provisions of this Convention, any income derived by a silent partner who is a resident of a Contracting State in respect of a silent partnership (in the case of Japan, Tokumei Kumiai) contract or another similar contract may be taxed in the other Contracting State according to the laws of that other Contracting State, provided that such income arises in that other Contracting State and is deductible in computing the taxable income of the payer in that other Contracting State.
Appears in 14 contracts
Samples: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation
SILENT PARTNERSHIP. Notwithstanding any other provisions of this Convention, any income and gains derived by a silent partner who is a resident of a Contracting State in respect of a silent partnership (in the case of Japan, Tokumei KumiaiKumiai and, in the case of Austria, Stille Gesellschaft) contract or another similar contract may be taxed in the other Contracting State in which such income and gains arise and according to the laws of that other Contracting State, provided that such income arises in that other Contracting State and is deductible in computing the taxable income of the payer in that other Contracting State.
Appears in 6 contracts
Samples: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation
SILENT PARTNERSHIP. Notwithstanding any other provisions of this Convention, any income and gains derived by a silent partner who is a resident of a Contracting State in respect of a silent partnership (in the case of Japan, Tokumei Kumiai) contract or another similar contract may be taxed in the other Contracting State in which such income and gains arise and according to the laws of that other Contracting State, provided that such income arises in that other Contracting State and is deductible in computing the taxable income of the payer in that other Contracting State.
Appears in 6 contracts
Samples: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation
SILENT PARTNERSHIP. Notwithstanding any other provisions of this Convention, any income and gains derived by a silent partner who is a resident of a Contracting State in respect of a silent partnership (in the case of Japan, Tokumei Kumiai) contract or another similar contract may be taxed in the other Contracting State in which such income and gains arise and according to the laws of that other Contracting State, provided that such income arises in that other Contracting State and is deductible in computing the taxable income of the payer in that other Contracting State.
Appears in 5 contracts
Samples: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation
SILENT PARTNERSHIP. Notwithstanding any other provisions of this Convention, any income derived by a silent partner who is a resident of a Contracting State in respect of a silent partnership (in the case of Japan, Tokumei KumiaiXxxxxxx Xxxxxx) contract or another similar contract may be taxed in the other Contracting State according to the laws of that other Contracting State, provided that such income arises in that other Contracting State and is deductible in computing the taxable income of the payer in that other Contracting State.
Appears in 4 contracts
Samples: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation
SILENT PARTNERSHIP. Notwithstanding any other provisions of this Convention, any income derived by a silent partner who is a resident of a Contracting State in respect of a silent partnership (in the case of Japan, “Tokumei Kumiai” and in the case of Peru, “Asociación en Participación”) contract or another similar contract may be taxed in the other Contracting State according to the laws of that other Contracting State, provided that such income arises in that other Contracting State and is deductible in computing the taxable income of the payer in that other Contracting State.
Appears in 4 contracts
Samples: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation
SILENT PARTNERSHIP. Notwithstanding any other provisions of this ConventionAgreement, any income derived by a silent partner who is a resident of a Contracting State in respect of a silent partnership (in the case of Croatia, “tajno društvo” and in the case of Japan, “Tokumei Kumiai”) contract or another similar contract may be taxed in the other Contracting State according to the laws of that other Contracting State, provided that such income arises in that other Contracting State and is deductible in computing the taxable income of the payer in that other Contracting State.
Appears in 4 contracts
Samples: Agreement for the Elimination of Double Taxation, Agreement for the Elimination of Double Taxation, Agreement for the Elimination of Double Taxation
SILENT PARTNERSHIP. Notwithstanding any other provisions of this Convention, any income and gains derived by a silent partner who is a resident of a Contracting State in respect of a silent partnership (in the case of Japan, Tokumei Kumiai) contract or another other similar contract may be taxed in the other Contracting State in which such income and gains arise and according to the laws of that other Contracting State, provided that such income arises in that other Contracting State and is deductible in computing the taxable income of the payer in that other Contracting State.
Appears in 3 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SILENT PARTNERSHIP. Notwithstanding any other provisions of this Convention, any income derived by a silent partner who is a resident of a Contracting State in respect of a silent partnership (in the case of Japan, Tokumei Kumiai) contract or another similar contract may be taxed in the other Contracting State according to the laws of that other Contracting State, provided that such income arises in that other Contracting State and is deductible in computing the taxable income of the payer in that other Contracting State.
Appears in 2 contracts
Samples: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation
SILENT PARTNERSHIP. Notwithstanding any other provisions of this Convention, any income derived by a silent partner who is a resident of a Contracting State in respect of a silent partnership (in the case of Japan, Tokumei Kumiai) contract or another similar contract may be taxed in the other Contracting State according to the laws of that other Contracting State, provided that such income arises in that other Contracting State and is deductible in computing the taxable income of the payer in that other Contracting State.
Appears in 2 contracts
Samples: Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation
SILENT PARTNERSHIP. Notwithstanding any other provisions of this Convention, any income derived by a silent partner who is a resident of a Contracting State in respect of contributions made pursuant to a silent partnership (in the case of Japan, Tokumei KumiaiXxxxxxx Xxxxxx) contract or another similar contract may be taxed in the other Contracting State according to the laws of that other Contracting State, provided that such income arises in that other Contracting State and is deductible in computing the taxable income of the payer in that other Contracting State.
Appears in 1 contract
