9911796707
TMI BlogApplication of Tax Agreements to Restrict a Party’s Right to Tax its Own ResidentsX X X X Extracts X X X X X X X X Extracts X X X X ..... racting Jurisdiction of its residents, except with respect to the benefits granted under provisions of the Covered Tax Agreement: a) which require that Contracting Jurisdiction to grant to an enterprise of that Contracting Jurisdiction a correlative or corresponding adjustment following an initial adjustment made by the other Contracting Jurisdiction, in accordance with the Covered Tax Agreement, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ered Tax Agreement; d) which require that Contracting Jurisdiction to provide a tax credit or tax exemption to Jurisdiction may tax in accordance with the Covered Tax Agreement (including profits that are attributable to a permanent establishment situated in that other Contracting Jurisdiction in accordance with the Covered Tax Agreement); e) which protect residents of that Contracting Jurisdictio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ments, annuities, alimony payments or other maintenance payments arising in the other Contracting Jurisdiction shall be taxable only in that other Contracting Jurisdiction; or j) which otherwise expressly limit a Contracting Jurisdiction s right to tax its own residents or provide expressly that the Contracting Jurisdiction in which an item of income arises has the exclusive right to tax that item ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ions have made such a notification with respect to a provision of a Covered Tax Agreement, that provision shall be replaced by the provisions of paragraph 1. In other cases, paragraph 1 shall supersede the provisions of the Covered Tax Agreement only to the extent that those provisions are incompatible with paragraph 1. - - statute, statutory provisions legislation, law, enactment, Acts, Rules, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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