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" As regards the application of the Convention at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning... "
Issues Presented by Proposals to Modify the Tax Treatment of Expatriation: A ... - Pagina 77
1995
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Staatsverträge im internationalen Steuerrecht: zur Rechtsnatur, Geschichte ...

Rudolf Weber-Fas - 1982 - 172 pagini
...Sinne auch die Auslegungsregel des OECD-Modells 1977: „As regards the application of the Convention by a Contracting State any term not defined therein...shall, unless the context otherwise requires, have the meaning which it has under the law of the State concerning the taxes to which the Convention applies"...
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United States Congressional Serial Set

1987 - 948 pagini
...solely between places in the other Contracting State. 2. As regards the application of the Convention by a Contracting State any term not defined therein shall, unless the context otherwise requires or the competent authorities agree to a common meaning pursuant to the provisons of Article 25 (Mutual...
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International Law Reports: Volume 72, Volumul 72

E. Lauterpacht - 1986 - 806 pagini
...convention of 1954 states that in the application of its provisions by one of the contracting parties any term not defined therein shall unless the context otherwise requires have the meaning which it has under the laws in force in the territory of that party relating to the taxes...
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International Law Reports, Volumul 72

E. Lauterpacht, C. J. Greenwood - 1987 - 812 pagini
...convention of 1954 states that in the application of its provisions by one of the contracting parties any term not defined therein shall unless the context otherwise requires have the meaning which it has under the laws in force in the territory of that party relating to the taxes...
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Congressional Serial Set

1992 - 858 pagini
...Economy and Finance or his authorized representative. 2. As regards the application of the Convention by a Contracting State any term not defined therein shall, unless the context otherwise requires, and subject to the provisions of Article 26 (Mutual Agreement Procedure), have the meaning which it...
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Festschrift für Karl Beusch zum 68. Geburtstag am 31. Oktober 1993

Karl Beusch - 1993 - 1010 pagini
...OECD Model Double Taxation Convention reads as follows: As regards the application of the Convention by a Contracting State any term not defined therein...shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which the Convention applies...
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Multilateral Tax Treaties

Helmut Loukota, Albert J. Rädler, Josef Schuch, Franz Wassermeyer, Gerald Toifl, Christoph Urtz - 1998 - 266 pagini
...partnership or association deriving its status as such from the laws in force in a Contracting State. 2. As regards the application of the Convention at any...shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purposes of the taxes to which...
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The Improper Use of Tax Treaties:With Particular Reference to the ...

Stef Weeghel - 1998 - 302 pagini
...1980 Netherlands-United Kingdom tax treaty provides, in line with the OECD Model Conventions, that 'any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which the Convention applies.'...
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Tax Treaty Interpretation

Michael Lang - 2001 - 402 pagini
...domestic law.37 2. The relevance of Art. 3 (2) Article 3 (2) of the OECD Model Tax Convention states that "as regards the application of the Convention at any...shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purposes of the taxes to which...
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The Impact of Community Law on Tax Treaties:Issues and Solutions

Pasquale Pistone - 2002 - 424 pagini
...includes the performance of professional services and of other activities of an independent character. 2. As regards the application of the Convention at any...shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purposes of the taxes to which...
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