Sayfa 315The Parties to this Convention,…
Recognising that governments lose substantial corporate tax revenue because of aggressive…
Mindful that base erosion and profit shifting (hereinafter referred to as “BEPS”)…
Recognising the importance of ensuring that profits are taxed where substantive economic…
Welcoming the package of measures developed under the OECD/G20 BEPS project (hereinafter…
Noting that the OECD/G20 BEPS package included tax treaty-related measures to address…
Conscious of the need to ensure swift, co-ordinated and consistent implementation…
Noting the need to ensure that existing agreements for the avoidance of double taxation…
Recognising the need for an effective mechanism to implement agreed changes in a…
PART I. SCOPE AND INTERPRETATION OF TERMS
Article 1 – Scope of the Convention…
This Convention modifies all Covered Tax Agreements as defined in subparagraph a)…
Article 2 – Interpretation of Terms…
1. For the purpose of this Convention, the following definitions apply:…
a) The term “Covered Tax Agreement” means an agreement for the avoidance of double…
i) that is in force between two or more:…
A) Parties; and/or…
B) jurisdictions or territories which are parties to an agreement described above…
ii) with respect to which each such Party has made a notification to the Depositary…
b) The term “Party” means:…
i) A State for which this Convention is in force pursuant to Article 34 (Entry into…
ii) A jurisdiction which has signed this Convention pursuant to subparagraph b) or…
c) The term “Contracting Jurisdiction” means a party to a Covered Tax Agreement.…
d) The term “Signatory” means a State or jurisdiction which has signed this Convention…
2. As regards the application of this Convention at any time by a Party, any term…
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LEXI size zaman kazandırır. Sonuç analizi, doküman asistanı ve araştırma modlarıyla LEXPERA içeriğine erişiminizi kolaylaştırır.
