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accordance Administration Agency America amount annuities application bond calendar carried citizen claim Commission compensation contracting corporation coupon Danish deemed Denmark dent Department derived derived from sources determination dividends duplicate enterprise entity excess tax exchange exempt from United Federal filed Form France French gross income holding imposed income tax industrial interest Internal Revenue Code Ireland Irish January labor laws letter of notification Management means ment nonresident alien individual Office otherwise owner paid Pakistan paragraph partnership paying payment pensions percent period permanent establishment person poration prescribed present Convention profits provisions provisions of Article real property received reduced rate Regulation relating release rentals resi resident respect royalties securities Service sources Sweden Swiss Switzerland tax withheld taxable taxation taxpayer term therein tion Title tracting trade or business United States tax unless vention withholding agent
Page 120 - annuity" means a stated sum payable periodically at stated times during life or during a specified or ascertainable period of time under an obligation to make the payments in return for adequate and full consideration in money or money's worth. Article...
Page 154 - State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions have accrued to one of the enterprises, but by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
Page 156 - Convention or for the prevention of fraud or the administration of statutory provisions against legal avoidance in relation to the taxes which are the subject of the present Convention. Any information so exchanged shall be treated as secret and shall not be disclosed to any person other than those concerned with the assessment and collection of the taxes which are the subject of the present Convention. No information shall be exchanged which would disclose any trade secret or trade process. (2)...
Page 156 - ... (2) The provisions of the present Convention shall not be construed to restrict in any manner any exemption, deduction, credit or other allowance now or hereafter accorded by the laws of one of the contracting States in the determination of the tax imposed by such State.
Page 137 - Interest on bonds, securities, notes, debentures, or on any other form of indebtedness derived from sources within one of the contracting States by a resident or corporation or other entity of the other contracting State not having a permanent establishment in the former State shall be exempt from tax by such former State.
Page 170 - Overseas Private Investment Corporation (Part 4301) XXXV Office of Personnel Management (Part 4501) XL Interstate Commerce Commission (Part 5001) XLI Commodity Futures Trading Commission (Part 5101...
Page 16 - Any information so exchanged shall be treated as secret and shall not be disclosed to any person other than those concerned with the assessment and collection of the taxes which are the subject of the present Convention. No information shall be exchanged which would disclose any trade, business, industrial or professional secret or any trade process.
Page 17 - XXI (1) The provisions of this Convention shall not be construed to deny or affect in any manner the right of diplomatic and consular officers to other or additional exemptions now enjoyed or which may hereafter be granted to such officers.