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Us Withholding Tax Agreement

4. Notwithstanding Articles XIV (Independent Personal Services) and XV (Personal Services on Demand), an amount paid by a resident of a contracting state to a residence in the other contracting state may be imposed to sign an agreement on the provision of an athlete`s services (with an amount covered in paragraph 1 of Article XV (dependant services) in the first country. For more information on the withholding of agents who pay income to foreign persons, including non-resident foreigners, foreign companies, foreign partnerships, foreign trusts, foreign estates, foreign governments and international organizations, see publication 515, withheld at source on foreign and foreign companies. 8. Foreign residents of a State party Ownership of a corporation or other organization, reorganization, merger, division or other transaction and benefit, profits or similar income relating to such alienation is not recognized for the purposes of taxation in that state, if the person acquiring the estate is invited to do so, the competent authority of the other contracting state may give its consent in order to avoid double taxation and to have conditions of double taxation. which are satisfactory for this competent authority to defer until that date and according to the terms provided by the agreement the recognition of the benefit, profit or income of these assets with respect to these assets for the purposes of taxation in that other state. This Convention does not affect the tax privileges of diplomatic or consular representatives under the general rules of international law or the provisions of specific agreements. (11) The competent authorities of the contracting states agree on the way in which this article is applied, including an arrangement, to ensure a level of assistance comparable to each contracting state. A tax treaty is a bilateral (bipartisan) agreement between two countries to resolve issues related to the double taxation of each citizen`s passive and active income.