Treaty on Global Currency Transactions Tax

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Treaty on Global Currency Transactions Tax

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PART II Currency [Exchange] Transaction Tax

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TITLE VI PLACE OF TAXABLE TRANSACTIONS

TITLE VI PLACE OF TAXABLE TRANSACTIONS

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ARTICLE 9

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§1 The place of a taxable transaction shall be deemed to be

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1. the place where the transferor of the currency has established his business or has a fixed establishment to which the transaction can be allocated or, in the absence of such a place of business or fixed establishment, the place where he has his permanent address or usually resides;

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2. the place where the transferee has established his business or has a fixed establishment to which the transaction can be allocated or, in the absence of such a place, the place where he has his permanent address or usually resides, when the transferor is established outside the territory of one of the Contracting States and the transferee is established in the territory of a Contracting State;

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3. the place where the intermediary has established his business or has a fixed establishment to which the transaction can be allocated when the transferor and the transferee are not established nor have a fixed establishment in the territory of one of the Contracting States and the intermediary has;

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4. the place of the payment or settlement, or the place of the dealing or trading, or the place of booking, in that successive order, if such place is situated within the territory of one of the Contracting States ,when the place of the transaction is not according to art 9 § 1, 1-3 situated within the territory of one of the contracting States

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5. within the Contracting State of which the currency, as meant in art. 8 § 3, is the currency of the transaction.

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§2 In order to avoid double taxation a Contracting State shall exempt transactions that are effectively taxed in another State under a CTT or a tax similar to the CTT when the place of the taxable transaction is situated outside the territory of that State according to art 9§ 1,1.

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