 | 2001 - 228 pages
...a preparatory or auxiliary character, for the resident. (4) A person acting in a Contracting State on behalf of a resident of the other Contracting State...whom paragraph (5) applies — shall be deemed to be a permanent establishment in the first-mentioned State if such person: (a) Has, and habitually exercises... | |
 | 1999 - 240 pages
...a preparatory or auxiliary character, for the resident. (4) A person acting in a Contracting State on behalf of a resident of the other Contracting State...whom paragraph (5) applies — shall be deemed to be a permanent establishment in the first-mentioned State if such person: (a) Has, and habitually exercises... | |
 | United States. Internal Revenue Service - 1968 - 1034 pages
...a preparatory or auxiliary character, for the resident. (4) A person acting in a Contracting State on behalf of a resident of the other Contracting State...whom paragraph (5) applies — shall be deemed to be a permanent establishment in the firstmentioned State if such person : (a) Has, and habitually exercises... | |
 | Great Britain - 1963 - 1436 pages
...Contracting State. (v) A person acting in one of the Contracting States on behalf of an enterprise of the other Contracting State — other than an agent of an independent status to whom subparagraph (i) (vi) applies — shall be deemed to be a permanent establishment in the former Contracting... | |
 | United States. Internal Revenue Service - 1971 - 816 pages
...have a preparatory or auxiliary character, for the resident. 4. A person acting in a Contracting State on behalf of a resident of the other Contracting State...to whom paragraph 5 applies — shall be deemed to be a permanent establishment in the first-mentioned State if such person has, and habitually exercises... | |
 | United States. Internal Revenue Service - 1976 - 624 pages
...permanent establishment under the Convention. Under paragraph (4) a person acting in one Contracting State on behalf of a resident of the other Contracting State,...independent status to whom paragraph (5) applies, will be deemed to be a permanent establishment in the firstmentioned Contracting State if such person... | |
 | United States. Internal Revenue Service - 1977
...Convention. Under paragraph (4) a person acting in one Contracting State on behalf of an enterprise of the other Contracting State, other than an agent...independent status to whom paragraph (5) applies, will be deemed to be a permanent establishment if such person has, and habitually exercises in that... | |
 | Hans Jörg Geiser, Pamela Alleyne, Carroll Gajraj - 1976 - 298 pages
...entertainers or athletes. 5. A person acting in a Schedule 1 State on behalf of an enterprise of a Schedule 2 State (other than an agent of an independent status to whom paragraph (1) applies), shall be deemed to be a permanent establishment in the Schedule 1 State — (a) if he... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1977 - 520 pages
...constitute a permanent establishment. Under paragraph (4), a person acting in one Contracting State on behalf of a resident of the other Contracting State,...independent status to whom paragraph (5) applies, will be deemed to constitute a permanent establishment if such person has. and habitually exercise... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1982 - 532 pages
...permanent establishment under the Convention. Under paragraph (4), a person acting in one Contracting State on behalf of a resident of the other Contracting State,...independent status to whom paragraph (5) applies, will be deemed to constitute a permanent establishment if such person has, and habitually exercises... | |
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A person acting in a Contracting State on behalf of an enterprise of the other Contracting State — other than an agent of an independent status to whom paragraph 5 applies — shall be deemed to be a permanent establishment... 
