Where by reason of the provisions. of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question and to determine the mode of application of the Convention to such person.
Appears in 7 contracts
Samples: www.iras.gov.sg, www.iras.gov.sg, 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, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual agreement and to determine the mode of application of the Convention to such person. In the absence of such agreement, such person shall not be considered to be a resident of either Contracting State for purposes of enjoying benefits under the Convention.
Appears in 5 contracts
Samples: internationaltaxtreaty.com, www.ris.bka.gv.at, www.parlament.gv.at
Where by reason of the provisions. of paragraph 1 a person other than an individual or a company is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement endeavour to settle the question and to determine the mode of application of the Convention to such person.
Appears in 1 contract
Samples: home.treasury.gov
Where by reason of the provisions. of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question and to determine the mode of application of the Convention to such personby mutual agreement.
Appears in 1 contract
Samples: Tax Agreement
Where by reason of the provisions. of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question by mutual agreement, having regard to the person’s place of effective management, the place where it is incorporated or constituted, and to determine any other relevant economic and material factors. In the mode absence of application such agreement, for the purposes of the Convention Convention, the person shall not be entitled to such personclaim any benefits provided by this Convention.
Appears in 1 contract
Samples: www.vmi.lt
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 shall by mutual agreement endeavour to settle the question and to determine the mode of application of the Convention to such personby mutual agreement.
Appears in 1 contract
Samples: Text of the Agreement
Where by reason of the provisions. of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement endeavour to settle the question and to determine the mode of application of the Convention Agreement to such person.
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, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question and by mutual agreement in order to determine the mode of application of the Convention to such person.
Appears in 1 contract
Samples: www.vmi.lt
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 by mutual agreement endeavour to settle the question and to determine the mode of application of the Convention to such personby mutual agreement.
Appears in 1 contract
Samples: aopsglobal-ng.com
Where by reason of the provisions. of paragraph 1 a person other than an individual or a company is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question and to determine the mode of application of the Convention to such person.
Appears in 1 contract
Samples: cypruslaw.narod.ru