Page 455 - ΔΟΚΙΜΗ

446 ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡΙΛΙΟΥ 1984
~ b) the gross income οΙ such person 1β not ueed ίη
8ubstantia1 part, direct1y or indirectly, to meet
1iabi1ities (inc1uding liabilities for interest or
royalties) to persons who are residents of a State
other than a Contraoting State and who are not
citizens ο! the United States.
For the purposes of subparagraph a), a corporation that has
substantia1 trading ίη its stock οη s recognized exchange ίΔ
a Contracting State is presumed to be owned by individual
residents ο! that Contraoting State. Α stock exchange shall
be treated Ββ a "recognized exchange" by agreement ο! the
oompetent authorities ο! the Contracting Ststes.
(2) Parsgraph 1 shal1 not app1y ί! it is deter.mined that
the estab1ishment, aoquisition~ maintenance ο! such
person and the conduct of its operations d1d not have ΒΒ a
prino1pa1 purpose obtaining benefits under the Convention.
(3) Wherea
β) lncome derived by a trustee i8 to be treated
for the purposes ο! this Convention ββ ihcome ο!
a resident ο! οηθ ο! the Contracting States; and
b.) the trustee derived the income ίη connection
with a scheme a principa1 purpose ο! which was to
obtain a benefit under this Convention,
then, notwithstanding any other provision ο! this Convention,
the Convention does not app1y ίη relation to that income.
Article 21
MUTUAL AGREEMENT FROCEDURE
(1) Where a resident of a Contracting State considers that
the actions of οηθ or both ο! the Contracting States result
or will result for him in taxation not ίη accordance with
this Convention, he may, notwithstanding the remedies
provided by the national laws of the Contracting Statee,
present his case to the competent suthority of the
Contracting State of which he ίθ a reeident. Shou1d the
resident' θ claim be considered t ·o have meri t by the
competent authority ο! the Contracting State to which the