Common use of Where Clause in Contracts

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, Agreement

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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

Samples: Agreement, Agreement, 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; and

Appears in 12 contracts

Samples: Agreement, Agreement, Agreement

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

Samples: Agreement, 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: treasury.gov.au, istracomaus.files.wordpress.com, www.survivefrance.com

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

Samples: Agreement, Agreement, www.legislation.gov.au

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: www.taxpolicy.ird.govt.nz, Agreement, taxpolicy.ird.govt.nz

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

Samples: Agreement, Agreement, Australia

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: internationaltaxtreaty.com, www.aph.gov.au, www.mof.go.jp

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 3 contracts

Samples: www.ris.bka.gv.at, www.parlament.gv.at, www.parlament.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 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: www.spenceclarke.com, Agreement, www.legislation.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 3 contracts

Samples: Taxation Avoidance Agreement, Agreement, Agreement

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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. (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: www.aph.gov.au, treasury.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: 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 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.mof.go.jp, www.ilajapan.org

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 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

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 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

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