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" Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have... "
United States Congressional Serial Set - Page 2
1987
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Congressional Serial Set

1992 - 858 pages
...reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having...shall apply only to the last-mentioned amount. In such case the excess part of the payments shall remain taxable according to the laws of each Contracting...
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Multilateral Tax Treaties

Helmut Loukota, Albert J. Rädler, Josef Schuch, Franz Wassermeyer, Gerald Toifl, Christoph Urtz - 1998 - 266 pages
...reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having...shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting...
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The Impact of Community Law on Tax Treaties:Issues and Solutions

Pasquale Pistone - 2002 - 424 pages
...reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having...which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions...
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Treaties and International Agreements Registered Or Filed and Recorded with ...

United Nations Staff - 2002 - 564 pages
...reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt- claim for which it is paid, exceeds the amount which would have been agreed upon by the payer...
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Treaty Series Volume 1965

536 pages
...reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having...shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting...
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Treaty Series Volume 1948 1996

460 pages
...reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having...shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting...
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tratey series vol.1909 1996

468 pages
...reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest having...shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting...
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Treaty Series Volume 2031

492 pages
...reason of a special relationship between the payer and the beneficiai owner or between both of them and some other person, the amount of the interest, having...shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting...
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Treaty Series Volume 1858 - 1995 - I. Nos. 31608-31656

486 pages
...person, the amount of the interest, having regard especially to the rate of interest or the amount of the debt-claim for which it is paid, exceeds the amount...shall apply only to the last-mentioned amount. In such case the excess part of the payments shall remain taxable according to the laws of each Contracting...
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Recueil Des Traités

2005 - 524 pages
...owing to a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having...which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions...
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