Diplomatic and Consular Officials

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..... des the provisions of this Convention: ARTICLE 10 OF THE MLI ANTI-ABUSE RULE FOR PERMANENT ESTABLISHMENT SITUATED IN THIRD JURISDICTIONS Paragraph 1 of Article 10 of the MLI Where: a. an enterprise of a [Contracting State] derives income from the other [Contracting State] and the first-mentioned [Contracting State] treats such income as attributable to a permanent establishment of the enterprise s .....

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..... f the income derived from the other [Contracting State] described in paragraph 1 [of Article 10 of the MLI] is derived in connection with or is incidental to the active conduct of a business carried on through the permanent establishment (other than the business of making, managing or simply holding investments for the enterprise s own account, unless these activities are banking, insurance or sec .....

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..... eceding sentence by a resident of the other [Contracting State] shall consult with the competent authority of that other [Contracting State] before either granting or denying the request. The following paragraph 1 of Article 7 of the MLI applies and supersedes the provisions of this Convention: ARTICLE 7 OF THE MLI PREVENTION OF TREATY ABUSE (Principal Purposes Test provision) Notwithstanding any .....

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