Congressional Serial SetU.S. Government Printing Office, 1992 |
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Page 18
... the amendments shall enter into force for any other Party on the thirtieth day after the date on which that Party deposits its instrument . 7 . After the entry into force of an amendment to this Convention or to a Protocol , any new ...
... the amendments shall enter into force for any other Party on the thirtieth day after the date on which that Party deposits its instrument . 7 . After the entry into force of an amendment to this Convention or to a Protocol , any new ...
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accordance with paragraph agreement amended application beginning of emplacement borehole Business Profits capital competent authorities consular officer consular post Contracting Convention Coordinating Group core samples Designated Personnel Team Designated Seismic Station dividends Double Taxation emplacement hole enterprise entry into force exempt explosive canister Federal Republic Finland fixed base German Democratic Republic Government hydrodynamic measurement zone hydrodynamic yield measurement Independent Personal Services installation International Registry investment meters non-standard configuration notification on-site inspection paid Parties otherwise agree Party carrying percent permanent establishment Personnel Team Leader planned date point of entry procedures Protocol provisions of Article provisions of paragraph purposes receiving recording facility registration related to verification Republic of Germany requirements resident royalties satellite hole seismometer Senate sending specific test specified in paragraph subparagraph taxable Taxes on Income territory Testing Party tion Transport Personnel Treaty United unless the Parties verification activities Verifying Party yield measurement method
Popular passages
Page 4 - Article 5. Permanent establishment 1. For the purposes of this Convention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment...
Page 13 - ... and b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State. 3. Notwithstanding the preceding provisions of this Article, remuneration...
Page 4 - Notwithstanding the preceding provisions of this Article. the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage. display or delivery of goods or merchandise belonging to the enterprise...
Page 8 - Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the recipient is the beneficial owner of the interest the tax so charged shall not exceed 10 per cent of the gross amount of the interest.
Page 70 - Any information received by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in relation to, the taxes covered by the Convention. Such persons or authorities shall use the information only for such purposes.
Page 48 - The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. Article 26. Exchange of Information ( 1 ) The competent authorities of the Contracting States...
Page 12 - State or capital situated therein. (2) Where by reason of the provisions of paragraph (1) an individual is a resident of both Contracting States, then his status shall be determined as follows: a) He shall be deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the...
Page 7 - Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State. 2. However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that State, but if the...
Page 8 - interest" as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a right to participate in the debtor's profits, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures.
Page 14 - ... from his personal activities as such exercised in the other Contracting State, may be taxed in that other State.