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Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or by movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, may be taxed in that other Contracting State. Molly Shaiken Volleyball Player uncredited. Vanessa Ross Restaurant Patron Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. The provisions of paragraphs 1 and 3 of this Article shall also apply to the income from immovable property of an enterprise and to income from immovable property used for the performance of independent personal services. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention. In witness whereof the undersigned, being duly authorized thereto, have signed this Protocol. With reference to Article 26 of the Convention, it is understood that the information exchanged according to the provisions of the said Article shall be used only for tax purposes as specified therein.

If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. Wayne Packer Googler uncredited. The provisions of paragraph 1 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency. Gains derived by a resident of a Contracting State from the alienation of shares or comparable interests deriving more than 50 per cent of their value directly or indirectly from immovable property situated in the other Contracting State, may be taxed in that other State. The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. Subject to the provisions of Articles 16, 18, 19 and 21 of this Convention, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. Each of the Contracting States shall notify to the other through diplomatic channels the completion of the procedures required by its law for the entry into force of this Convention.

This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein. Capital represented by immovable property referred to in Article 6 of this Convention, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting State.

Am Fong Restaurant Patron uncredited. Chasty Ballesteros Exotic Dancer 1. Yang Wa Zao uncredited. The provisions of gyakornoiok 1 and 3 of this Article shall also apply to the income from immovable inline of an enterprise and to income from immovable property used for the performance of independent personal services.

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However, if Hungary finds out in the future that its obligations under this Convention are inconsistent with the requirements that apply to Hungary as a member of the European Union, both Contracting States may consult each other about the possible amendments of the Convention. If information is requested by a Contracting State in accordance with this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though that other State may not need such information for its own tax purposes.

The exchange of information is not restricted by Articles 1 and 2 of this Convention. Margie Cox Elektra Cosplayer uncredited. Jean Whalen Eve uncredited. John Goodman Sammy Boscoe. Natalia Smith Air Hockey Girl uncredited.

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Have agreed as follows:. The competent authority shall endeavour, if the objection appears to onlinf to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with this Convention. In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the business of the permanent establishment, including executive and general administrative expenses so incurred, whether in the Contracting State in which the permanent establishment is situated or elsewhere.

Gains from the alienation of any property, other than that referred yun in the preceding paragraphs of this Article, shall be taxable only in the Contracting State of which the alienator is a resident. In witness whereof the undersigned, being duly authorized thereto, have signed this Protocol.

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Jarion Monroe Not Professor X. Capital represented by ships and aircraft operated by an enterprise of a Contracting State in international traffic and by movable property pertaining to the operation of such ships and aircraft shall be taxable only in the Contracting State in which the place of effective onlie of the enterprise is situated.

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Heather Rae Young Exotic Dancer 2. The provisions of this Convention shall also apply to any identical or substantially similar taxes that are imposed by either Contracting State after the date of signature of this Convention in addition to, or gyakrnokok place of, the existing taxes. Sergey Brin Sergey Brin uncredited.

Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. The Contracting States may consult each other before a resident of a Contracting State is denied relief from taxation in the other Contracting State by reason of the preceding sentence. Where in accordance with any provision of the Convention income derived or capital owned by a resident of a Contracting State is exempt from tax in that State, such State may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.

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As regards the application of this Convention at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purposes of the taxes to which this Convention applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State. Star Phyfe Newgooler uncredited. In the case of Hungary:.

Bilan Walker Noogler uncredited. Ships and aircraft shall not be regarded as immovable property. However, no such deduction shall be allowed in respect of amounts, if any, paid otherwise than towards reimbursement of actual expenses by the permanent establishment to the head office of the enterprise or any of its other offices, by way of royalties, fees or other similar payments in return for the use of patents or other rights, or by way of commission, for specific services performed or for management, or, except in the case of a banking enterprise, by way of income from debt-claims with regard to moneys lent to the permanent establishment.

Penalty charges for late payment shall not be regarded as income from debt-claims for the purpose of this Article. Thomas Dalby Chinatown Pedestrian uncredit In witness whereof the undersigned, being duly authorized thereto, have signed this Convention.

This term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources.

Steven Wiig Chinatown Pedestri In no case shall the provisions of paragraph 3 of this Article be construed to permit a Contracting State to decline to supply information solely because the information is held by a bank, other financial institution, nominee or person acting in an agency or a fiduciary capacity or because it relates to ownership interests in a person.

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Nothing in this Article shall affect the operation of any law of a Contracting State relating to tax imposed on profits from insurance relating to risks situated in that State with non-residents. Nothing in this Convention shall affect the fiscal privileges of members of diplomatic missions or consular posts under the general rules of gyzkornokok law or under the provisions of special agreements.

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