Where. by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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.
Appears in 11 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
Where. by reason of owing to a special relationship between the payer and the beneficial owner recipient or depositor or between both of them and some other person, the amount of the interestinterest paid, having regard to the debt-debt- claim or deposit for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner recipient or depositor in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such that case, the excess part of the payments shall remain taxable according to the laws law of each the Contracting State, due regard being had to State in which the other provisions of this Agreementinterest arises.
Appears in 9 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
Where. by reason of owing to a special relationship between the payer and the beneficial owner recipient or between both of them and some other person, the amount of the interestinterest paid, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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.
Appears in 8 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Avoidance Agreement
Where. by reason of owing to a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interestinterest paid, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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.
Appears in 5 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Convention for the Avoidance of Double Taxation
Where. by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-debt claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-last mentioned amount. In such 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.
Appears in 5 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Double Taxation Agreement
Where. by reason of owing to a special relationship between the payer and the beneficial owner recipient or between both of them and some other person, the amount of the interestinterest paid, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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.
Appears in 5 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
Where. by reason of owing to a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interestinterest exceeds, having regard to the debt-claim for which it is paidwhatever commercial reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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.
Appears in 5 contracts
Samples: Avoidance of Double Taxation Agreement (Dta), Avoidance of Double Taxation Agreement (Dta), Avoidance of Double Taxation Agreement
Where. by reason of owing to a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interestinterest paid exceeds, having regard to the debt-claim for which it is paidwhatever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner paid in the absence of such relationship, the provisions of this Article shall apply only to the last-last mentioned amount. In such 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.
Appears in 4 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
Where. by reason of owing to a special relationship between the payer and the beneficial owner recipient or between both of them and some other person, the amount of the interestinterest paid, having regard to the debt-debt- claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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.
Appears in 4 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
Where. by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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 AgreementConvention.
Appears in 4 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 owing to a special relationship between the payer and the beneficial owner recipient or between both of them and some other person, the amount of the interestinterest paid, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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 AgreementConvention.
Appears in 3 contracts
Samples: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
Where. by reason of owing to a special relationship between the payer and the beneficial owner recipient or between both of them and some other person, the amount of the interestinterest paid, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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.
Appears in 3 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Agreement
Where. by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interestinterest paid exceeds, having regard to the debt-claim for which it is paidwhatever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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 AgreementConvention.
Appears in 3 contracts
Samples: Double Taxation Agreement, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Where. by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable taxable, according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion, Double Taxation Avoidance Agreement
Where. by reason of owing to a special relationship between the payer and the beneficial owner recipient or between both of them and some other person, the amount of the interestinterest paid, having regard to the debt-claim indebtedness for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments payment shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement.
Appears in 3 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
Where. by reason of a special relationship between the payer and the beneficial owner owner, or between both of them and some other person, persons the amount of the interest, having regard to the debt-claim for which it is technical fees paid, exceeds for whatever reasons, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments payment shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
Where. by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a 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 AgreementConvention.
Appears in 2 contracts
Samples: Agreement for Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Where. by reason of owing to a special relationship between the payer and the beneficial owner recipient or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is interest paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments payment shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
Where. by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments payment shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Where. by reason of there is a special relationship between the payer and the beneficial owner or between both of them and some other person, person and the amount of the interestinterest exceeds, having regard to the debt-claim for which it is paidwhatever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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 AgreementConvention.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Where. by reason of owing to a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interestinterest paid, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
Where. by reason of owing to a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim interest paid exceeds for which it is paid, exceeds whatever reason the amount which would have been agreed upon by the payer and the beneficial owner paid in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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.
Appears in 2 contracts
Samples: Double Taxation Agreement, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
Where. by reason of owing to a special relationship between the payer and the beneficial owner recipient or between both of them and some other person, the amount of the interestinterest paid, having regard to the debt-βclaim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-βmentioned amount. In such 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.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement
Where. by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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.
Appears in 2 contracts
Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion, Double Taxation Avoidance Agreement
Where. by reason of owing to a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interestinterest exceeds, having regard to the debt-claim for which it is paidwhatever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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.
Appears in 2 contracts
Samples: Income Tax Treaty, Avoidance of Double Taxation Agreement
Where. by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interestincome from debt-claims, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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 AgreementConvention.
Appears in 1 contract
Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
Where. by reason of a special relationship between the payer and the beneficial owner or between be- tween both of them and some other person, the amount of the interest, having regard to the debt-debt- claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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.
Appears in 1 contract
Where. by reason of owing to a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interestinterest exceeds, having regard to the debt-claim for which it is paidwhatever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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.
Appears in 1 contract
Samples: Double Taxation Relief Agreement
Where. by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-last- mentioned amount. In such 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.
Appears in 1 contract
Where. by reason of a special relationship between the payer and the beneficial owner or between both of them them, and some other person, the amount of the interest, interest having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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.
Appears in 1 contract
Where. by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interestinterest paid, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a 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.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
Where. by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim debtclaim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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.
Appears in 1 contract
Where. by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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.
Appears in 1 contract
Samples: Agreement for Avoidance of Double Taxation of Income and the Prevention of Fiscal Evasion
Where. by reason of a special relationship between the payer and the beneficial owner or between be- tween both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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 AgreementConvention.
Appears in 1 contract
Where. by reason of owing to a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interestinterest exceeds, having regard to the debt-claim for which it is paidwhatever commercial reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-last- mentioned amount. In such 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.
Appears in 1 contract
Samples: Income Tax Treaty
Where. by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, third person, the amount of interest , given the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amountlast . In such this 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 AgreementConvention.
Appears in 1 contract
Where. by reason of there is a special relationship between the payer and the beneficial owner or between both of them and some other person, and the amount of the interest, having regard to the debt-claim interest exceeds for which it is paid, exceeds whatever reason the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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 AgreementConvention.
Appears in 1 contract
Where. by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such 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 AgreementConvention.
Appears in 1 contract