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420
ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡΙΛΙΟΥ
1984
(h) The term "international tra:ttic"
σιθΒηθ
8.l13
tTansport
by
ship or aircraft, except where euch
transport is 801e1y betweell places
ίη
the other
Contracting State;
(1)
The reference to a rate of tax or tax burden
wh1ch
is
"substantially less than" means less than
50
percellt of.
(2)
ΑΑΙ
other term used in th1s Convention
and
not defined
in
'h18
Oonvention shall, unless the context otherwise
requlree,
have the meaning which it has under the
laws of
'h8 Contracting
State whose tax 1s being determined.
Notwlth8tanding
the preceding sentence, if the meaning
of
aaoh •
'β~
under the laws
ο!
a
Contracting State
1s
41ttereA'
tro8
the meaning
of
the term under the laws of
....'h8r Contracting
State, or 1f the meaning
ο!
such
a
.... 1.
ΩΟ'
readil.r determinable under the
laws o:t a
Contracting state, the competent authorities of the
Contracting statee may,
ίη
o·rder to prevent double
taxation or to further
any
other purpose of this
Convention, establieh a common meaning of the term
for the purposes of this Convention.
Article
3
FISCAL RESIDENCE
(1)
Ιη
this Convention:
(a) The term "resident of Cyprus" mesnst
(i)
Α
Cypriot corporation; and
(i1)
Any
person (except a corporation)
resident
ίη
Cyprus for the purposes of its tax, but in
the case of income derived or paid
by
a partnership,
estate, or trust this term applies only to the extent
that the income derived by such person 1s subject to
Cypriot tax
βθ
the income of a resident either
ίη
its
hands or
ίη
the hands of its partners or beneficiariee.
(b) The term "resident
ο"!
the United States" means:
(i)
Α
United States corporation; and
(11)
Α
United States citizen and
&n3
person
(except a corporation) resident
ίη
the United