Where. (a) a resident of a Contracting State is beneficially entitled, whether directly or through one or more interposed trust estates, to a share of the business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate other than a trust estate which is treated as a company for tax purposes; and
Appears in 27 contracts
Samples: Agreement, Agreement, Taxation Avoidance Agreement
Where. (a) a resident of a one of the Contracting State States is beneficially entitled, whether directly or through one or more interposed trust estates, to a share of the business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate other than a trust estate which is treated as a company for tax purposes; and
Appears in 13 contracts
Where. (a) a resident of a Contracting State is beneficially entitled, owns (whether directly as a direct beneficiary of a trust or through one or more interposed trust estates, to trusts) a share of the profits of a business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate other than a trust estate which is treated as a company for tax purposes; and
Appears in 12 contracts
Where. (a) a resident of a Contracting State is beneficially entitledowns, whether directly or through one or more interposed trust estatestrusts, to a share of the business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate other than a trust estate which is treated as a company for tax purposes; and
Appears in 12 contracts
Samples: Agreement, Double Taxation Avoidance Agreement, Agreement
Where. (a) a resident of a Contracting State is beneficially entitled, whether directly or through one or more interposed trust estates, to a share of the business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate other than a trust estate which is treated as a company for tax purposes; and
Appears in 9 contracts
Samples: Agreement, Agreement, www.aph.gov.au
Where. (a) a resident of a Contracting State is beneficially entitled, whether directly or indirectly through one or more interposed trust estatestrusts, to a share of the business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate other than a trust estate which is treated as a company for tax purposes; and
Appears in 6 contracts
Where. (a) a resident of a one of the Contracting State States is beneficially entitled, whether directly or through one or more interposed trust estates, to a share of the business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate other than a trust estate which is treated in that other State as a company for tax purposes; and
Appears in 5 contracts
Where. (a) a resident of a Contracting State is beneficially entitled, owns (whether directly as a direct beneficiary of a trust or through one or more interposed trust estates, to trusts) a share of the profits of a business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate other than a trust estate which is treated as a company for tax purposes; and
Appears in 5 contracts
Samples: Agreement, www.taxpolicy.ird.govt.nz, internationaltaxtreaty.com
Where. (a) a resident of a Contracting State is beneficially entitled, whether directly or through one or more interposed trust estatestrusts, to a share of the profits derived from business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate (other than a trust estate which is treated as a company for tax purposes) in its capacity as trustee; and
Appears in 4 contracts
Samples: www.mofa.go.jp, www.aph.gov.au, www.mof.go.jp
Where. (a) a resident of a Contracting State is beneficially entitled, whether directly or indirectly through one or more interposed trust estatestrusts, to a share of the business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate other than a trust estate which is treated as a company for tax purposes; : and
Appears in 3 contracts
Samples: Agreement, Taxation Avoidance Agreement, Agreement
Where. (a) a resident of a Contracting State is beneficially entitled, whether directly or through one or more interposed trust estatestrusts, to a share of the business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate other than a trust estate which is treated as a company for tax purposes; and
Appears in 3 contracts
Samples: Agreement, Taxation Avoidance Agreement, www.worldlii.org
Where. (a) a resident of a one of the Contracting State States is beneficially entitled, whether directly or through one or more interposed trust estatestrusts, to a share of the business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate other than a trust estate which is treated as a company for tax purposes; and
Appears in 3 contracts
Samples: Agreement, www.legislation.gov.au, www.spenceclarke.com
Where. (a) a resident of a one of the Contracting State States is beneficially entitled, whether directly or indirectly through one or more interposed trust estatestrusts, to a share of the business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate other than a trust estate which is treated as a company for tax purposes; and
Appears in 3 contracts
Samples: Double Taxation Avoidance Agreement Between Malaysia and Australia, Double Taxation Avoidance Agreement, phl.hasil.gov.my
Where. (a) a resident of a Contracting State is beneficially entitledowns, whether directly or through one or more interposed trust estatestrusts, to a share of the business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate other than a trust estate which is treated as a company for tax purposes; and
Appears in 2 contracts
Samples: www.parlament.gv.at, www.ris.bka.gv.at
Where. (a) a resident of a Contracting State is beneficially entitled, whether directly or through one or more interposed trust estatestrusts, to a share of the profits derived from business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate (other than a trust estate which is treated as a company for tax purposes) in its capacity as trustee; and
Appears in 2 contracts
Samples: www.ilajapan.org, www.mof.go.jp
Where. (ai) a resident of a Contracting State is beneficially entitled, whether directly or through one or more interposed trust estates, to a share of the business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate other than a trust estate which is treated as a company for tax purposes; and
Appears in 2 contracts
Samples: treasury.gov.au, www.aph.gov.au
Where. (a) a. a resident of a Contracting State is beneficially entitled, whether directly or through one or more interposed trust estates, to a share of the business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate other than a trust estate which is treated as a company for tax purposes; and
Appears in 2 contracts
Samples: Agreement, Taxation Avoidance Agreement
Where. (a) a resident of a Contracting State is beneficially entitledowns, whether directly or through one or more interposed trust estatestrusts, to a share of the business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate other than a trust estate which is treated as a company for tax purposes; purposes; and
Appears in 1 contract
Samples: www.sii.cl
Where. (a) a a)a resident of a one of the Contracting State States is beneficially entitled, whether directly or through one or more interposed trust estates, to a share of the business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate other than a trust estate which is treated as a company for tax purposes; and
Appears in 1 contract
Samples: Agreement
Where. (a) a resident of a Contracting State is beneficially entitled, whether directly or through one or more interposed trust estates, to a share of the business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate other than a trust estate which is treated as a company for tax purposespurpose; and
Appears in 1 contract
Samples: internationaltaxtreaty.com
Where. (a) a resident of a Contracting State is I s beneficially entitled, whether directly or through one or more interposed trust estatestrusts, to a share of the profits derived from business profits of an enterprise carried on in the other Contracting State by the trustee of a trust estate (other than a trust estate which is treated as a company for tax purposes) in its capacity as trustee; and
Appears in 1 contract
Samples: www.taxpolicy.ird.govt.nz
