 | Great Britain - 1963 - 1436 pages
...other person, the amount of the royalty or the sum paid, having regard to the use, right or property for which it is paid, exceeds the amount which would...recipient in the absence of such relationship, the provisions of the preceding paragraphs of this Article shall apply only to the last-mentioned amount.... | |
 | United States. Internal Revenue Service - 1977
...to the use, right, or information for which they are paid, exceeds the amount which would have been of the Treasury, Internal Revenue Service shall remain taxable according to the law of each Contracting State, due regard being had to the other... | |
 | United States. Internal Revenue Service - 1971 - 816 pages
...information for which they are paid, exceeds the amount which would have been agreed upon by the payor and the recipient in the absence of such relationship,...amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being Convention. ARTICLE... | |
 | Hans Jörg Geiser, Pamela Alleyne, Carroll Gajraj - 1976 - 298 pages
...them and some other person, the amount of the payment made exceeds the amount which would have been agreed upon by the payer and the recipient in the...last-mentioned amount. In that case the excess part of the payment shall remain taxable according to the laws of the Schedule 1 State or Schedule 2 State, as... | |
 | 1987 - 948 pages
...both of them and some other person, the amount of the interest, having regard to the indebtedness on which it is paid, exceeds the amount which would have...amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other... | |
 | 1973 - 444 pages
...effectively connected to such permanent establishment. In such a case, the provisions of Article 6 shall apply. (5) The term "interest" as used in this...the laws of each Contracting State, due regard being had to the otter provisions of this Convention. (8) Interest received by one of the Contracting States,... | |
 | United States. Congress. Joint Committee on Internal Revenue Taxation - 1962 - 726 pages
...shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 6. Where, owing to a special relationship between the...amount. In that case, the excess part of the payments shall remain taxable according to the Contracting States' own laws, due regard being had to the other... | |
 | 468 pages
...both of them and some other person, the amount of the interest paid, having regard to the debt-claim for which it is paid, exceeds the amount which would...amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other... | |
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... for which it is paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this article shall apply only to the last-mentioned amount. In that case, the excess part... 