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Modern agreements apply to persons who are residents of one or both of the two countries. »Ê¹ÚÌåÓýapp significance of this restriction may be judged by the consequences of its absence from the 1945 United States agreement, in the case of CIR v Commerzbank (63TC218). In that case, it was held that a German bank and a Brazilian bank were both entitled to relief under the agreement between the United Kingdom and the United States.