With regard to Article 12 Sample Clauses

With regard to Article 12. Where a resident of a Contracting State receives payments for the use of, or the right to use, industrial, commercial or scientific equipment, from sources in the other Contracting State, such resident may elect to be taxed in the Contracting State in which such royalties arise, as if the right or property in respect of which such royalties are paid is effectively connected with a permanent establishment or fixed base in that Contracting State. In such case, the provisions of Article 7 or Article 14 of this Convention shall, as the case may be, apply to the income and deduction attributable to such right or property.
Sample 1
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With regard to Article 12. If Kazakhstan agrees in a treaty with another country which at the time of signing the Convention is a member of the Organisation for Economic Cooperation and Development, to impose a lower rate on royalties than the rate specified in paragraph 2, both Contracting States shall apply that lower rate instead of the rate specified in paragraph 2 in regard of the following:
Sample 1

Related to With regard to Article 12

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