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. In the absence of such agreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.
Appears in 9 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
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 agreementagreement and determine the mode of application of the Agreement to such person. In the absence of such agreement, for the purposes of the Convention, 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 Conventionunder the Agreement.
Appears in 8 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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. In the absence of Until such agreementagreement has not been reached, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.
Appears in 8 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
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 agreementagreement and determine the mode of application of the Agreement to such person. In the absence of such agreement, such person shall not 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.
Appears in 7 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Double Taxation 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 endeavour to settle the question by mutual agreementagreement and determine the mode of application of the Convention to such person. In the absence of such agreement, for the purposes of the Convention, 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.
Appears in 7 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
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. In the absence of such agreement, agreement 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.
Appears in 4 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement for the Avoidance of Double Taxation
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. In the absence of such agreement, agreement 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.
Appears in 3 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Convention for the Avoidance of Double Taxation
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 agreementquestion. In the absence of such agreement, such person shall not 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.
Appears in 3 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation 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 endeavour to settle the question by mutual agreement. In the absence of such agreement, such person shall not 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.
Appears in 3 contracts
Samples: Income Tax Convention, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
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. In the absence of such agreement, such person shall not 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.
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
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. In the absence of such agreement, for the purposes of the ConventionAgreement, the person shall not be entitled to claim any benefits provided by this ConventionAgreement.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 agreementagreement 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, for the purposes of the ConventionAgreement, the person shall not be entitled to claim any benefits provided by this ConventionAgreement.
Appears in 3 contracts
Samples: Double Taxation Avoidance Agreement (Dtaa), Double Taxation Agreement, Double Taxation Agreement
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 agreementagreement and determine the mode of application of the Convention to such person. In the absence of such agreement, 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.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Double Taxation Avoidance 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 agreementand to determine the mode of application of the Convention to such person. In the absence of such agreement, such person 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".
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
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 Convention to such person. In the absence of such agreement, for the purposes of the Convention, the such person shall not be entitled to claim any benefits relief or exemption from tax provided by this the Convention.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
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 agreementagreement 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, for the purposes of the ConventionAgreement, the person shall not be entitled to claim any benefits provided by this ConventionAgreement.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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. In the absence of such an agreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
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 agreementagreement and determine the mode of application of the Convention to such person. In the absence of such agreement, 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.
Appears in 1 contract
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. In the absence of such agreement, such person 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".
Appears in 1 contract
Samples: Income Tax Treaty
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. In the absence of such agreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.
Appears in 1 contract
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. In the absence of such agreement, for the purposes of the Convention, the agreement such person shall not be entitled considered to claim any benefits provided by be outside the scope of this ConventionAgreement.
Appears in 1 contract
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 agreementagreement and determine the mode of application of this Agreement to such person. In the absence of such agreement, 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.
Appears in 1 contract
Samples: Tax Residency 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 endeavour to settle the question by mutual agreement. In the absence of such agreement, for the purposes of the ConventionAgreement, the person shall not be entitled to claim any benefits provided by this Conventionthe Agreement.
Appears in 1 contract
Samples: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion
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 agreementagreement having regard in particular to its place of effective management, the place where it is incorporated or otherwise constituted and any other relevant factors. In the absence of such agreement, for the purposes of the Convention, the such person shall not be entitled to claim any benefits relief or exemption from tax provided by this the Convention.
Appears in 1 contract
Samples: Income Tax 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 agreementagreement and determine the mode of application of this Agreement to such person. In the absence of such agreement, 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.
Appears in 1 contract
Samples: Double Taxation Agreement
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 agreementquestion. In the absence of such agreement, such person shall not 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.
Appears in 1 contract
Samples: Double Taxation 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 endeavour to settle the question by mutual agreement. In If the absence of competent authorities do not reach such an agreement, for the purposes of the Convention, 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.
Appears in 1 contract
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. In the absence any of such agreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.
Appears in 1 contract
Samples: Income and Capital Tax 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 procedure endeavour to settle the question by mutual agreementand determine the mode of application of the Convention to such person. In the absence of such agreement, for mutual agreement by the purposes of the Conventioncompetent authorities, the person shall not be entitled to claim any benefits relief or exemption from tax provided by this the Convention.
Appears in 1 contract
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 agreementagreement due regard being had to its place of effective management or to any other relevant criterion. In the absence of such and agreement, for the purposes of the Convention, the such a person shall not be entitled to claim any benefits provided by under this Convention.
Appears in 1 contract
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. In the absence of such agreementcome to an agreement in 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.
Appears in 1 contract
Samples: Income and Capital Tax 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. In the absence of such agreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.
Appears in 1 contract
Samples: Income and Capital Tax 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 agreementagreement procedure. In the absence of such a mutual agreement, 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.
Appears in 1 contract
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 agreementagreement having regard to its place of effective management. In the absence of such agreement, for the purposes of the Convention, the such person shall not be entitled to claim any benefits relief or exemption from tax provided for by this the Convention.
Appears in 1 contract
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 agreementand to determine the mode of application of the Convention to such person. In the absence of such agreement, for the purposes of the Convention, the such person shall not be entitled to claim any benefits relief or exemption from tax provided by this the Convention.
Appears in 1 contract
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. In the absence of Until such agreementagreement 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.
Appears in 1 contract
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 agreementagreement and determine the mode of application of the Agreement to such person. In the absence of such agreement, for the purposes of the ConventionAgreement, the person shall not be entitled to claim any benefits provided by this ConventionAgreement.
Appears in 1 contract
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. In the absence of such agreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.
Appears in 1 contract
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 agreementagreement procedure. In the absence of such a mutual agreement, 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.
Appears in 1 contract
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. In the absence of such agreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.
Appears in 1 contract
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 Convention to such person. In the absence of such agreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.
Appears in 1 contract
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 agreementquestion. In the absence of such agreement, for the purposes of the Convention, the such person shall not be entitled to claim any benefits relief or exemption from tax provided by this the Convention.
Appears in 1 contract
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. In the absence of such agreement, 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.
Appears in 1 contract
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. In the absence of such agreement, for the purposes of the Convention, the person shall not be entitled to claim any benefits provided by this Convention.
Appears in 1 contract
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. In the absence of such agreement, for the purposes of the ConventionAgreement, the person shall not be entitled to claim any benefits provided by this Convention.the Agreement. Article 5
Appears in 1 contract
Samples: Income and Capital Tax Agreement