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the beneficial owner is a resident of the other Contracting State … States which wish to make this more explicit (...) then be applied to determine if that person beneficially owns that payment, or if that person is acting (...) the income is allocated under residence State principles to determine if that person is the beneficial owner
Language:English
Score: 1486878.3 - https://www.un.org/esa/ffd/wp-...0/6STM_BeneficialOwnership.pdf
Data Source: un
of beneficial ownership] makes plain that the State of source is not obliged to give up taxing rights…merely (...) of “beneficial owner” make it clear that the meaning given to this term in the context of the Article must (...) of “beneficial owner” make it clear that the meaning given to this term in the context of the Article must
Language:English
Score: 1324663.3 - https://www.un.org/esa/ffd/wp-...ation_Beneficial-Ownership.pdf
Data Source: un
.........................................................................................................................23 4.2. Beneficial ownership (...) ...............................................................................................................................38 Bibliography on Beneficial Ownership (...) or investment, but in order to make the income fall within the protection of a certain treaty. There is, however
Language:English
Score: 1273728.4 - https://www.un.org/esa/ffd/wp-...5/20130530_Paper2A_Wheeler.pdf
Data Source: un
drafted for inclusion before the relevant quoted passages on beneficial ownership. This headnote makes (...) concerning the meaning of “beneficial owner” make it clear that the meaning given to this term in the context (...) of “beneficial owner” make it clear that the meaning given to this term in the context of the Article must
Language:English
Score: 1270442.9 - https://www.un.org/esa/ffd/wp-...ntion_beneficial-ownership.pdf
Data Source: un
as the recipient is the beneficial owner of the income, the benefits of Article 10, 11, 12 or 12.1 (...) of the Convention should not be denied. The object and purpose of the beneficial owner requirement is to prevent (...) , royalties, or fees for technical services as nominees, agents or conduits for the beneficial owners
Language:English
Score: 1234198.8 - https://www.un.org/esa/ffd/wp-...eps-general-anti-avoidance.pdf
Data Source: un
systems can make it difficult to determine whether a CIV is a company, or respectively, a person (...) to such investment) makes the tax treatment of collective investment vehicles an important question for both (...) at reasonable cost are in particular beneficial to small investors. However, institutional investors
Language:English
Score: 1222310.2 - https://www.un.org/esa/ffd/wp-...e-Investment-Vehicles-CIVs.pdf
Data Source: un
industry, and other stakeholders, to work together towards a mutually beneficial goal of promoting (...) predictive decision- making and promote greater partnerships across all aviation stakeholders. C/CAR/DCA/13 (...) together towards a mutually beneficial goal of promoting continuous improvement to the safety, efficiency
Language:English
Score: 1213781.9 - https://www.icao.int/NACC/Docu...13/CCARDCA13/CCARDCA13WP14.pdf
Data Source: un
Russell calls provably beneficial AI, which can help us solve problems and “make changes in the world (...) Is ‘provably beneficial’ AI possible? - ITU Hub This website will offer limited functionality (...) Standardization Development Search the site Search Close search form Is ‘provably beneficial’ AI possible? Home
Language:English
Score: 1210626.2 - https://www.itu.int/hub/2020/0...ovably-beneficial-ai-possible/
Data Source: un
explanations concerning the meaning of “beneficial owner” make it clear that the meaning given to this term (...) to determine qualified profits. However, where the beneficial owner belongs to a multinational enterprise group (...) of that State, but if the beneficial owner of the income is a resident of the other Contracting State, the tax
Language:English
Score: 1205541 - https://www.un.org/development...zation%2026%20April%202021.pdf
Data Source: un
of beneficial ownership to make clear who can be entitled to the treaty benefits. 2. A proposal by a previous (...) review will offer an opportunity to consider the concept of beneficial ownership throughout the UN Model (...) TAX CONVENTION – 2014 UPDATES Articles 10, 11 & 12 – Beneficial owner concept – The OECD found
Language:English
Score: 1202899.5 - https://www.un.org/esa/ffd/wp-...d-and-Developing-Countries.pdf
Data Source: un