Entitlement to Benefits. Notwithstanding the other provisions of this Agreement, a benefit under this Agreement shall not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of this Agreement.
Appears in 40 contracts
Sources: Agreement for the Elimination of Double Taxation, Agreement for the Elimination of Double Taxation With Respect to Taxes on Income, Agreement for the Elimination of Double Taxation
Entitlement to Benefits. 1. Notwithstanding the other provisions of this Agreement, a benefit under this Agreement shall not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of this Agreement.
Appears in 4 contracts
Sources: Double Taxation Agreement, Agreement for the Elimination of Double Taxation, Ataf Model Agreement for the Elimination of Double Taxation
Entitlement to Benefits. Notwithstanding the other any provisions of this Agreement, a benefit under this Agreement shall not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of this Agreement.
Appears in 3 contracts
Sources: Agreement for the Elimination of Double Taxation, Agreement for the Elimination of Double Taxation, Agreement for the Elimination of Double Taxation
Entitlement to Benefits. Notwithstanding the other provisions of this Agreement, a benefit under this Agreement shall not be granted in respect of an item of income or capital if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of this Agreement.
Appears in 2 contracts
Sources: Agreement for the Elimination of Double Taxation, Agreement for the Elimination of Double Taxation
Entitlement to Benefits. Notwithstanding the other any provisions of this Agreement, a benefit under this Agreement Agree- ment shall not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction transac- tion that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of this Agreement.
Appears in 1 contract
Sources: Double Tax Agreements (Guernsey) Amendment Order 2020
Entitlement to Benefits. Notwithstanding the other provisions of this Agreement, a benefit under this Agreement shall not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting grant- ing that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of this Agreement.
Appears in 1 contract
Sources: Double Taxation Agreement
Entitlement to Benefits. Notwithstanding the other provisions of this Agreement, a benefit under this Agreement Agree- ment shall not be granted in respect of an item of income if it is reasonable to concludecon- clude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly di- rectly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant rele- vant provisions of this Agreement.
Appears in 1 contract
Sources: Double Tax Agreement