The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1969 - Administrative law The Code of Federal Regulations is the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government. |
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Common terms and phrases
15 percent annuities application Article VII Article XI Belgian Congo Belgium calendar citizen commercial profits Commissioner of Internal competent authorities Contracting Party coupon bond interest deemed dends derived from sources dividends paid domestic corporation engaged in trade entity estate or trust excess tax withheld exempt from United Federal fiduciary filed Finland Finnish foreign corporation Form gross income income tax interest paid Internal Revenue Code items of income letter of notification means ment nent establishment Netherlands nonresident alien individual Norway notify the withholding owner Pakistan paragraph partnership payment period permanent establishment personal services poration present Convention provisions of Article rate of tax rate of United real property reduced rate resident or corporation spect suant tax at source tax imposed tax was withheld taxable years beginning taxpayer term United territory tion trade or business United States corporation United States dollars United States enterprise United States tax vention withholding agent withholding of United
Popular passages
Page 136 - State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
Page 135 - permanent establishment" when used with respect to an enterprise of one of the Contracting Parties means a branch, management, factory or other fixed place of business, but does not include an agency unless the agent has, and habitually exercises, a general authority to negotiate and conclude contracts on behalf of such enterprise or has a stock of merchandise from which he regularly fills orders on its behalf. An enterprise of one of the Contracting Parties shall not be deemed to have a permanent...
Page 78 - State through a permanent establishment situated therein, there shall be attributed to such permanent establishment the industrial or commercial profits which it might be expected to derive if it were an independent enterprise engaged in the same or similar activities under the same or similar conditions and dealing at arm's length with the enterprise of which it is a permanent establishment.
Page 94 - Parties) as is necessary for carrying out the provisions of the present Convention or for the prevention of fraud or the administration of statutory provisions against legal avoidance in relation to the taxes which are the subject of the present Convention. Any information so exchanged shall be treated as secret and shall not be disclosed to any person other than those concerned with the assessment and collection of the taxes which are the subject of the present Convention. No information shall be...
Page 92 - permanent establishment", when used with respect to an enterprise of one of the Contracting States, means a branch, factory, or other fixed place of business, but does not include an agency unless the agent has, and habitually exercises, a general authority to negotiate and conclude contracts on behalf of such enterprise or has a stock of merchandise from which he regularly fills orders on behalf of such enterprise.
Page 34 - XX (1) The provisions of the present Convention shall not be construed to restrict In any manner any exemption, deduction, credit or other allowance accorded by the laws of one of the Contracting States in the determination of the tax imposed by such State.
Page 192 - Except where such authority is expressly given by this title to any person other than an officer or employee of the Treasury Department, the Secretary or his delegate shall prescribe all needful rules and regulations for the enforcement of this title, including all rules and regulations as may be necessary By reason of any alteration of law in relation to internal revenue.
Page 22 - pensions", as used in this Article, means periodic payments made in consideration for services rendered or by way of compensation for injuries received. (4) The term "life annuities", as used in this Article, means a stated sum payable periodically at stated times during life, or during a specified number of years, under an obligation to make the payments in return for adequate and full consideration in money or money's worth. ARTICLE...
Page 302 - XVI (1) The competent authorities of the contracting States shall exchange such information (being information available under the respective taxation laws of the contracting States) as is necessary for carrying out the provisions of the present Convention or for the prevention of fraud or the like in relation to the taxes which are the subject of the present Convention.
Page 47 - With respect to the provisions of this convention relating to exchange of information, service of documents and mutual assistance in the collection of taxes, such authorities may, by common agreement, prescribe rules concerning matters of procedure, forms of application and replies thereto, conversion of currency, disposition of amounts collected, minimum amounts subject to collection and related matters.