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Limitation on benefits provision
| Глоссарий по налогам |
Tax treaty provisions designed to restrict treaty-shopping opportunities by limiting treaty benefits to persons who meet one of several enumerated tests, which may require minimum level qualifications, e.g. local ownership.
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Provisions, английский
- All sorts of food necessary for the subsistence of the army and navy. those shipped on board for the officers and crew of any vessel, including merchant-ships, are held in a policy of insurance, as part of her outfit.
- Резервы на покрытие возможных потерь
Opportunities, английский
In general: conditions that allow for advancement, progress or profi t. in the policy context, circumstances for action with the attribute of a chance character. for example, the anticipation of additional benefi ts that may go along with the deployment of renewable energy (enhanced energy access and energy security, reduced local air pollution) but are not intentionally targeted. see also co-benefi ts and drivers.
Enumerated, английский
Qualifications, английский
- Национальный совет профессиональной квалификации
- Квалификационные требования
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Underlying tax, английский
Tax which is charged on corporate income out of which dividends are paid, but which does not appear as a direct deduction or withholding from the dividend itself.
Tiebreaker rule, английский
Tax treaty provision designed to prevent an individual from being deemed resident, for purpose of the treaty, in both treaty countries. generally a multi-step procedure will be provided to resolve the problem of dual residence, usually the place of a permanent home available being the first criterion.
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