Dual resident entities: treaty relief hinges on competent authorities agreeing a single jurisdiction of residence, otherwise relief denied. Competent authorities must endeavour to agree on a single Contracting Jurisdiction of residence for persons other than individuals, considering factors such as place of effective management and place of incorporation; absent such agreement, the person is generally not entitled to treaty relief or exemption except as the competent authorities may agree. Paragraph 1 supplants or operates in the absence of conflicting treaty rules for non-individual residents, excluding specific rules for dual listed companies, and Parties may notify the Depositary or reserve application as provided.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Dual resident entities: treaty relief hinges on competent authorities agreeing a single jurisdiction of residence, otherwise relief denied.
Competent authorities must endeavour to agree on a single Contracting Jurisdiction of residence for persons other than individuals, considering factors such as place of effective management and place of incorporation; absent such agreement, the person is generally not entitled to treaty relief or exemption except as the competent authorities may agree. Paragraph 1 supplants or operates in the absence of conflicting treaty rules for non-individual residents, excluding specific rules for dual listed companies, and Parties may notify the Depositary or reserve application as provided.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
