 | Hans Jörg Geiser, Pamela Alleyne, Carroll Gajraj - 1976 - 298 pages
...carries on business in a Schedule 2 State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. 9. The fact that an enterprise of a Schedule 1 State maintains in a Schedule 2 State a fixed place... | |
 | 1981 - 40 pages
...carries on business in that other country (whether through a permanent establishment or otherwise) will not of itself constitute either company a permanent establishment of the other. Article 6. Income from Immovable Property (Reed property) The proposed treaty provides that income... | |
 | 1987 - 948 pages
...carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. ARTICLE 6: INCOME FROM IMMOVABLE PROPERTY (REAL PROPERTY) 1. Income from immovable (real) property... | |
 | 1990 - 66 pages
...business in that other country (whether through a permanent establishment or otherwise) does not in and of itself constitute either company a permanent establishment of the other. The proposed treaty provides a special rule for the determination of the existence of a permanent establishment... | |
 | 1992 - 858 pages
...carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. ARTICLE 6 Income From Real Property (Immovable Property) 1. Income derived by a resident of a Contracting... | |
 | Daniel Sandler - 1998 - 326 pages
...carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. Commentary 40. It is generally accepted that the existence of a subsidiary company does not, of itself,... | |
 | Pasquale Pistone - 2002 - 424 pages
...carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment... | |
 | United Nations Staff - 2002 - 564 pages
...carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. Article 6. Income from Immovable Property 1 . Income derived by a resident of a Contracting State from... | |
 | Charles Haccius - 2004 - 1399 pages
...the "control" by a company RCO resident in State R of another company SCO resident in State S "shall not of itself constitute either company a permanent establishment" of the other for the purposes of the State R-State S tax treaty. The words "shall not of itself are important. Article... | |
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The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or... 
