Common use of Where, owing to a special Clause in Contracts

Where, owing to a special. relationship between the payer and the recipient or between both of them and some other person, the amount of interest paid, having regard to the indebtedness for which it is paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship and dealing with each other at arm's length, the provisions of this Article shall apply only to the last- mentioned amount. In that case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Where, owing to a special. relationship between the payer and the recipient beneficial owner or between both of them and some other person, the amount of the interest paid, having regard to the indebtedness paid exceeds for which it is paid, exceeds whatever reason the amount which would have been agreed upon by the payer and the recipient paid in the absence of such relationship and dealing with each other at arm's lengthrelationship, the provisions of this Article shall apply only to the last- last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Where, owing to a special. relationship between the payer and the recipient or between both of them and some other person, the amount of the interest paid, having regard to the indebtedness debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship and dealing with each other at arm's lengthrelationship, the provisions of this Article article shall apply only to the last- last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Where, owing to a special. relationship between the payer and the recipient of the interest or between both of them and some other person, the amount of the interest paidpaid exceeds, having regard to the indebtedness for which it is paidwhatever reason, exceeds the amount which would have been agreed upon by the payer and the recipient paid in the absence of such relationship and dealing with each other at arm's lengthrelationship, the provisions of this Article shall apply only to the last- mentioned amount. In that case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Where, owing to a special. relationship between the payer and the recipient or between both of them and some other person, the amount of the interest paid, having regard to the indebtedness debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship and dealing with each other at arm's lengthrelationship, the provisions of this Article shall apply only to the last- last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement.