With reference to Article 4. It is understood that the term “resident of a Contracting State” includes a pension fund or a pension scheme recognized and controlled according to statutory provisions of a Contracting State, which is generally exempt from income taxation in that State, and which is operated principally to administer or provide pension or retirement benefits or to earn income for the benefit of one or more such arrangements.
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With reference to Article 4. It is understood that the term “resident of a Contracting State” includes a pension fund or includes
a) a pension scheme recognized and controlled according to statutory provisions of a Contracting State, which is generally exempt from income taxation established in that State, ; and
b) an organisation that is established and which is operated principally exclusively for religious, charitable, scientific, cultural, or educational purposes (or for more than one of those purposes) and that is a resident of that State according to administer its laws, notwithstanding that all or provide pension part of its income or retirement benefits or to earn income for gains may be exempt from tax under the benefit domestic law of one or more such arrangementsthat State.
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Sources: Double Taxation Agreement