Activity provision. “The foregoing provisions shall not apply where the com- pany is engaged in substantive business operations in the Contracting State of which it is a resident and the relief from taxation claimed from the other Contracting State is with respect to income that is connected with such operations.”
Appears in 3 contracts
Sources: Double Taxation Convention, Double Taxation Convention, Double Taxation Convention
Activity provision. “The foregoing provisions shall not apply where the com- pany is engaged in substantive business operations in the Contracting State of which it is a resident and the relief from taxation claimed from the other Contracting State is with respect to income that which is connected with such operationsoper- ations.”
Appears in 2 contracts
Sources: Model Double Taxation Convention, Model Double Taxation Convention
Activity provision. “The foregoing provisions shall not apply where the com- pany is engaged in substantive business operations in the Contracting State of which it is a resident and the relief from taxation claimed from the other Contracting State is with respect to income that which is connected with such operationsoper- ations.”
Article 1 Commentary
Appears in 1 contract
Sources: Model Double Taxation Convention