Common use of Where by reason Clause in Contracts

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement. Until such agreement has not been reached, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement. Until In the absence of such agreement has not been reachedagreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement. Until such agreement has not been reached, for and determine the purposes mode of application of the ConventionConvention to such person. In the absence of such agreement, the such person shall not be entitled considered to claim any be a resident of either Contracting State for purposes of enjoying benefits provided by this under the Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement and determine the mode of application of the Agreement to such person. In the absence of such agreement. Until , such agreement has person shall not been reached, be considered to be a resident of either Contracting State for the purposes of enjoying benefits under the Convention, the person shall not be entitled to claim any benefits provided by this ConventionAgreement.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual agreementand determine the mode of application of the Agreement to such person. Until In the absence of such agreement has not been reached, such person shall be considered to be outside the scope of the Agreement except for the purposes provisions of the Convention, the person shall not be entitled to claim any benefits provided by this ConventionArticle 24.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour by mutual agreement procedure endeavor to settle the question by mutual question. If the competent authorities do not reach such an agreement. Until such agreement has not been reached, for the purposes of the Convention, the that person shall not be entitled to claim any benefits benefit provided by this the Convention, except those provided by paragraph 1 of Article 22 (Relief from Double Taxation), by paragraph 1 of Article 23 (Non-Discrimination) and by Article 24 (Mutual Agreement Procedure).

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement. Until In the absence of such agreement has agreement, such person shall not been reached, be considered to be a resident of either Contracting State for the purposes of enjoying benefits under the Convention, the person shall not be entitled to claim any benefits provided by this Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement. Until In the absence of such agreement has not been reachedagreement, for the purposes of the ConventionAgreement, the person shall not be entitled to claim any benefits provided by this ConventionAgreement.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement having regard to the person's place of incorporation, the place of effective management and any other relevant factors. In the absence of such agreement. Until such agreement has not been reached, for the purposes of the ConventionAgreement, the person shall not be entitled to claim any benefits provided by this ConventionAgreement.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual agreementand determine the mode of application of the Agreement to such person. Until In the absence of such agreement has not been reached, such person shall be considered to be outside the scope of the Agreement except for the purposes provisions of the Convention, the person shall not be entitled to claim any benefits provided by this ConventionArticle 25.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement. Until In the absence of such agreement has not been reachedagreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.. Permanent Establishment‌

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement having regard in particular to its place of effective management, the place where it is incorporated or otherwise constituted and any other relevant factors and to determine the mode of application of the Convention to such person. In the absence of such agreement. Until , such agreement has person shall be deemed not been reached, to be a resident of either Contracting State for the purposes of the Convention, the person shall not be entitled Articles 6 to claim any benefits provided by this Convention22 inclusive and Article 24.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual question. In the absence of such agreement. Until , such agreement has person shall not been reached, be considered to be a resident of either Contracting State for the purposes of enjoying benefits under the Convention, the person shall not be entitled to claim any benefits provided by this ConventionAgreement.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour endeavor to settle the question by mutual agreement. Until In the absence of such agreement has agreement, such person shall not been reached, be considered to be a resident of either Contracting State for the purposes of enjoying benefits under the Convention, the person shall not be entitled to claim any benefits provided by this Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual agreement. Until such agreement has not been reached, for and to determine the purposes mode of application of the ConventionConvention to such person. In the absence of such agreement, the such person shall not be entitled to claim any benefits relief or exemption from tax provided by this the Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement. Until such agreement has not been reached, for and determine the purposes mode of application of the ConventionAgreement to such person. In the absence of such agreement, the such person shall not be entitled considered to claim any be a resident of either Contracting State for purposes of enjoying benefits provided by this Convention.under the Agreement. Permanent Establishment

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement having regard to the person’s place of incorporation, the place of effective management and any other relevant factors. In the absence of such agreement. Until such agreement has not been reached, for the purposes of the ConventionAgreement, the person shall not be entitled to claim any benefits provided by this ConventionAgreement.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement. Until such agreement has not been reached, for having regard to the purposes person's place of the Conventioneffective management, the place where it is incorporated or constituted, and any other relevant factors. In the absence of such agreement, such person shall not be entitled considered to claim any be a resident of either Contracting State for purposes of enjoying benefits provided by this under the Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, . the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement. Until In the absence of such agreement has not been reachedan agreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual and to determine the mode of application of the Convention to such person. In the absence of such agreement. Until , such agreement has not been reachedperson shall be considered to be outside the scope of this Convention, except for the purposes Article "Exchange of the Convention, the person shall not be entitled to claim any benefits provided by this ConventionInformation".

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement, having regard to the person’s place of effective management, the place where it is incorporated or constituted, and any other relevant economic and material factors. Until In the absence of such agreement has not been reachedagreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention, except that such person may claim the benefits of Article 24 and Article 25.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, States the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement and determine the mode of application of the Convention to such person. In the absence of such agreement. Until such agreement has not been reached, for the purposes of the Convention, the person shall in each Contracting State be deemed not to be entitled to claim any benefits provided by this Conventiona resident of the other Contracting State.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement, having regard to the person's place of effective management, the place where it is incorporated or constituted, and any other relevant economic and material factors. Until In the absence of such agreement has not been reachedagreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement. Until such agreement has not been reached, for the purposes having regard in particular to its place of the Conventioneffective management, the place where it is incorporated or otherwise constituted and any other relevant factors. In the absence of such agreement, such person shall not be entitled to claim any benefits relief or exemption from tax provided by this the Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle its status and to determine the question by mutual agreementapplication of the Agreement. Until Insofar as no such agreement has not been reached, such person shall be deemed not to be a resident of either Contracting State for the purposes of enjoying benefits under the Convention, provisions of the person shall not be entitled to claim any benefits provided by this ConventionAgreement.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual question. In the absence of such agreement. Until , such agreement has not been reached, for the purposes of the Convention, the person shall not be entitled to claim any benefits relief or exemption from tax provided by this the Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by my mutual agreement and determine the mode of application of the Convention to such person. In the absence of such agreement. Until such agreement has not been reached, for the purposes of the Convention, the person shall in each Contracting State be deemed not to be entitled to claim any benefits provided by this Conventiona resident of the other Contracting State.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement. Until In the absence of such agreement has not been reachedagreement, for the purposes of the ConventionAgreement, the person shall not be entitled to claim any benefits provided by this Conventionthe Agreement.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual and to determine the mode of application of the Convention to such person. In the absence of such agreement. Until such agreement has not been reached, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement, having regard to the person’s place of effective management, the place where it is incorporated or constituted, and any other relevant economic and material factors. Until In the absence of such agreement has not been reachedagreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement procedure. In the absence of a mutual agreement. Until such agreement has not been reached, for the purposes of the Convention, the person shall not be entitled to claim any benefits relief or exemption from tax provided by this the Convention.. PERMANENT ESTABLISHMENT

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement procedure endeavour to settle the question by mutual agreementquestion. Until In the absence of such agreement has not been reached, for by the purposes competent authorities of the ConventionContracting States, the person shall not be entitled to claim any benefits relief or exemption from tax provided for by this Convention, except as provided for by paragraph 2 of Article 23 of this Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour endeavor to settle the question by mutual agreement procedure. In the absence of a mutual agreement. Until such agreement has not been reached, for the purposes of the Convention, the person shall not be entitled to claim any benefits benefits, relief or exemption from tax provided by this the Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour endeavor to settle the question by mutual agreement and determine the mode of application of this Agreement to such person. In the absence of such agreement. Until such agreement has not been reached, for the purposes of the Conventionthis Agreement, the such person shall not be entitled considered to claim any be a resident of either Contracting State for purposes of enjoying benefits provided by under this ConventionAgreement.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States State shall endeavour to settle resolve the question case by mutual agreement due regard being had to its place of effective management or to any other relevant criterion. In the absence of such and agreement. Until , such agreement has not been reached, for the purposes of the Convention, the a person shall not be entitled to claim any benefits provided by under this Convention.

Where by reason. of the provisions of paragraph 1 Paragraph 1, a person other than an individual is a resident of both Contracting States, the Contracting States shall undertake whatever is possible to resolve the case by mutual agreement. In case the competent authorities of the Contracting States shall endeavour fail to settle the question by mutual agreement. Until such come to an agreement has not been reachedin this respect, for the purposes of the Convention, the said person shall not be entitled to claim any of the tax benefits provided by or exemptions contemplated in this Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual question. In the absence of such agreement. Until , such agreement has person shall not been reached, be considered to be a resident of either Contracting State for the purposes of enjoying benefits under the Convention, the person shall not be entitled to claim any benefits provided by this ConventionAgreement.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement. Until In the absence of such agreement has not been reachedagreement, for the purposes of the ConventionAgreement, the person shall not be entitled to claim any benefits provided by this Convention.the Agreement. Article 5

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement and determine the mode of application of this Agreement to such person. In the absence of such agreement. Until such agreement has not been reached, for the purposes of the Conventionthis Agreement, the such person shall not be entitled considered to claim any be a resident of either Contracting State for purposes of enjoying benefits provided by under this ConventionAgreement.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States State shall endeavour to settle the question by mutual agreement. Until In the absence of such agreement has not been reachedagreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement. Until such agreement has not been reached, for and determine the purposes mode of application of the ConventionAgreement to such person. In the absence of such agreement, the such person shall not be entitled considered to claim any be a resident of either Contracting State for purposes of enjoying benefits provided by this Convention.under the Agreement. PERMANENT ESTABLISHMENT

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement. Until If the competent authorities do not reach such agreement has not been reached, for the purposes of the Conventionan agreement, the respective person shall be treated as a resident of neither Contracting State and shall not be entitled to claim any derive benefits provided by under this Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual agreementand determine the mode of application of the Convention to such person. Until In the absence of such agreement has not been reached, such person shall be considered to be outside the scope of the Convention except for the purposes provisions of the Convention, the person shall not be entitled to claim any benefits provided by this ConventionArticle 27.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual and to determine the mode of application of the Agreement to such person. In the absence of such agreement. Until , such agreement has not been reachedperson shall be considered to be outside the scope of this Agreement, except for the purposes Article "Exchange of the Convention, the person shall not be entitled to claim any benefits provided by this Conventioninformation".

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement. Until In the absence of such agreement has not been reachedagreement, for the purposes of the ConventionAgreement, the person shall not be entitled to claim any benefits provided by this ConventionAgreement except to the extent and in such manner as may be agreed upon by the competent authorities of the Contracting States.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual agreementand to determine the mode of application of the Agreement to such person. Until In the absence of such agreement has not been reached, for the purposes of the Convention, the such person shall not be entitled considered to claim any benefits provided by be outside the scope of this ConventionAgreement.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement and determine the mode of application of the Agreement to such person. In the absence of such agreement. Until such agreement has not been reached, for the purposes of the ConventionAgreement, the person shall not be entitled to claim any benefits provided by this ConventionAgreement.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to may settle the question by mutual agreement. Until In the absence of such agreement has not been reachedagreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement, having regard to the person's place of effective management and any other relevant economic and material factors. Until In the absence of such agreement has not been reachedagreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual or a trust is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement having regard to its place of effective management. In the absence of such agreement. Until , such agreement has not been reached, for the purposes of the Convention, the person shall not be entitled to claim any benefits relief or exemption from tax provided for by this the Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement. Until such agreement has not [sic] been reached, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour endeavor to settle the question by mutual agreement. Until such agreement has not been reached, for the purposes having regard to its place of the Conventioneffective management, the place of main or head office, place of incorporation, or any other relevant factors. In the absence of such agreement, such person shall not be entitled to claim any benefits provided by under this Convention, except that such person may claim the benefits of Articles 23 (Non•discrimination) and 24 (Mutual agreement procedure).

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement. Until In the absence of such agreement has not been reachedagreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.. Article 5

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement procedure endeavour to settle the question by mutual agreement. Until such agreement has not been reached, for and determine the purposes mode of application of the ConventionConvention to such person. In the absence of mutual agreement by the competent authorities, the person shall not be entitled to claim any benefits relief or exemption from tax provided by this the Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities then his status shall be determined as follows: If he is a national of both Contracting States, the Contracting States shall endeavour to settle the question by mutual agreement. Until such In the absence of a mutual agreement has not been reached, for between the purposes competent authorities of the ConventionContracting Parties, the such person shall not be entitled to claim any benefits relief or exemption from tax provided by this Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual or a company is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual agreement. Until such agreement has not been reached, for and to determine the purposes mode of application of the ConventionConvention to such person. In the absence of such agreement, the such person shall not be entitled to claim any benefits relief or exemption from tax provided by this the Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall sha l endeavour to settle set le the question by mutual agreement procedure. In the absence of a mutual agreement. Until such agreement has not been reached, for the purposes of the Convention, the person shall not be entitled to claim any benefits benefits, relief or exemption from tax provided by this the Convention.

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement, having regard to the person's place of effective management and any other relevant economic and material factors. Until In the absence any of such agreement has not been reachedagreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.