Application of Tax Agreements to Restrict a Party’s Right to Tax its Own Residents

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....ion by a Contracting 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 C....

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....olar who meets the conditions of the Covered 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); ....

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....n that other Contracting Jurisdiction; i) which provide that pensions and similar payments, 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 ....