Diplomatic Agents and Consular Officers

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....rticle 10 of the MLI apply and supersede the provisions of this Convention: ARTICLE 10 OF THE MLI - ANTI-ABUSE RULE FOR PERMANENT ESTABLISHMENTS SITUATED IN THIRD JURISDICTIONS Paragraph 1 of Article 10 of the MLI 1. Where: a) an enterprise of a [Contracting State] derives income from the other [Contracting State] and the first-mentioned [Contracting State] treats such income ....

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.... Article 10 of the MLI 2. Paragraph 1 [of Article 10 of the MLI] shall not apply if 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 fo....

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....e competent authority of the [Contracting State] to which a request has been made under the preceding 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 Conventio....