Common use of Where by reason Clause in Contracts

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall determine that the person is a resident of a Contracting State for the purposes of this Agreement by mutual agreement.

Appears in 12 contracts

Samples: Agreement, Agreement, Agreement

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Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall determine by mutual agreement the Contracting State of which that the person is shall be deemed to be a resident of a Contracting State for the purposes of this Agreement by mutual agreementAgreement.

Appears in 10 contracts

Samples: Agreement, Agreement, Agreement

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this Convention. In the absence of a mutual agreement by the competent authorities of the Contracting States, the person is shall not be considered a resident of a either Contracting State for the purposes of this Agreement claiming any benefits provided by mutual agreementthe Convention, except those provided by Articles 23 and 24.

Appears in 7 contracts

Samples: app.parlamento.pt, www.mofa.go.jp, www.mof.go.jp

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall endeavour to determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this Convention. In the absence of a mutual agreement by the competent authorities of the Contracting States, the person is shall not be considered a resident of a either Contracting State for the purposes of this Agreement claiming any benefits provided by mutual agreementthe Convention, except those provided by Articles 21, 22 and 23.

Appears in 6 contracts

Samples: assets.publishing.service.gov.uk, data.parliament.uk, www.regeringen.se

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall determine that the person is a resident of a Contracting State for the purposes of this Agreement his residential status by mutual agreement.

Appears in 5 contracts

Samples: Agreement, Agreement, Agreement

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall determine that endeavour by mutual agreement to deem, for purposes of the Convention, the person is to be a resident of a one Contracting State for the purposes of this Agreement by mutual agreementonly.

Appears in 4 contracts

Samples: www.revenue.ie, tayros.bg, www.dfa.ie

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall endeavour to determine by mutual agreement the Contracting State of which that person shall be deemed to be a resident for the purposes of this Agreement. In the absence of a mutual agreement by the competent authorities of the Contracting States, the person is shall not be considered a resident of a either Contracting State for the purposes of this Agreement claiming any benefits provided by mutual agreementthe Agreement, except those provided by Articles 21, 23 and 24.

Appears in 3 contracts

Samples: data.parliament.uk, www.rsl.org.ls, assets.publishing.service.gov.uk

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities it shall be deemed to be a resident of the Contracting States shall determine that State under the person is a resident laws of a Contracting State for the purposes of this Agreement by mutual agreementwhich it derives its status as such.

Appears in 3 contracts

Samples: Agreement, Agreement, Agreement

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall determine by mutual agreement the Contracting State of which that the person is shall be deemed to be a resident of a Contracting State for the purposes of this Agreement by mutual agreementConvention, having regard to the place of its head or main office, its place of effective management and any other relevant factors.

Appears in 2 contracts

Samples: www.mofa.go.jp, www.mof.go.jp

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall determine by mutual agreement the Contracting State of which that the person is shall be deemed to be a resident of a Contracting State for the purposes of this Agreement by mutual agreementConvention.

Appears in 2 contracts

Samples: www.mofa.go.jp, www.mof.go.jp

Where by reason. of the provisions of paragraph 1 1, a person other than an individual is a resident of both Contracting States, it shall be deemed to be a resident of the State in which it is incorporated; if the person under the foregoing criterion is still a resident of both Contracting States, then the competent authorities of the Contracting States shall determine that settle the person is a resident of a Contracting State for the purposes of this Agreement question by mutual agreement.

Appears in 2 contracts

Samples: Taxation Avoidance Agreement, soliq.uz

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall endeavour to determine by mutual agreement the Contracting State of which that the person is shall be deemed to be a resident of a Contracting State for the purposes of this Agreement by mutual agreementConvention, having regard to the place of its head or main office, its place of effective management and any other relevant factors.

Appears in 2 contracts

Samples: www.mof.go.jp, www.mofa.go.jp

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities it shall be deemed to be a resident of the Contracting States shall determine that the person State in which it is a resident of a Contracting State for the purposes of this Agreement by mutual agreementincorporated.

Appears in 2 contracts

Samples: Taxation Avoidance Agreement, internationaltaxtreaty.com

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Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of shall determine by mutual agreement the Contracting States State of which that person shall determine that the person is be deemed to be a resident of a Contracting State for the purposes of this Agreement by mutual agreementConvention.

Appears in 1 contract

Samples: internationaltaxtreaty.com

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall endeavour to determine by mutual agreement the Contracting State of which that the person is shall be deemed to be a resident of a Contracting State for the purposes of this Agreement by mutual agreementConvention, having regard to all relevant factors.

Appears in 1 contract

Samples: assets.publishing.service.gov.uk

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall determine by mutual agreement the Contracting State of which that the person is shall be deemed to be a resident of a Contracting State for the purposes of this Agreement by mutual agreementthe Convention.

Appears in 1 contract

Samples: www.jetro.go.jp

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the State under the laws of which it derives its status as such. The competent authorities of the Contracting States shall determine that endeavour to settle the person is a resident of a Contracting State for the purposes of this Agreement question by mutual agreementagreement and determine the mode of application of the Convention to such person.

Appears in 1 contract

Samples: auditors.am

Where by reason. of the provisions of paragraph 1 1, a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States its status shall determine that the person is a resident of a Contracting State for the purposes of this Agreement be determined by mutual agreement.

Appears in 1 contract

Samples: Taxation Avoidance Agreement

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall endeavour to determine that by mutual agreement the Contracting State of which such person is shall be deemed to be a resident of a Contracting State for the purposes of this Agreement by mutual agreementthe Convention, having regard to its place of effective management, the place where it is incorporated or otherwise constituted and any other relevant factors.

Appears in 1 contract

Samples: www.llv.li

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall determine that by mutual agreement the Contracting State of which such person is shall be deemed to be a resident of a Contracting State for the purposes of this Agreement by mutual agreementthe Agreement.

Appears in 1 contract

Samples: Agreement

Where by reason. of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then the competent authorities of the Contracting States shall determine that endeavour by mutual agreement to deem, for purposes of the Convention, the person is to be a resident of a one Contracting State for the purposes of this Agreement by mutual agreement.only. Permanent Establishment‌

Appears in 1 contract

Samples: www.revenue.ie

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