 | 1980 - 476 pages
...he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the indebtedness on which...interest Is paid was incurred, and such interest is borne by such permanent establishment, then such interest shall be deemed to be from sources within... | |
 | 1974 - 436 pages
...he is a resident ol a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the indebtedness on which...Interest Is paid was Incurred, and such Interest is borne by such permanent establishment, then such Interest shall be deemed to be from sources within... | |
 | 1999 - 240 pages
...he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the indebtedness on which...interest is paid was incurred, and such interest is borne by such permanent establishment, then such interest shall be deemed to be from sources within... | |
 | United States. Internal Revenue Service - 1968 - 1034 pages
...he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the indebtedness on which...interest is paid was incurred, and such Interest is borne by such permanent establishment, then such interest shall be deemed to be from sources within... | |
 | United States. Internal Revenue Service - 1976 - 624 pages
...(whether or not such person is a resident of a Contracting State) has a permanent establishment in a Contracting State in connection with which the indebtedness...interest is paid was incurred and such interest is borne by the permanent establishment, the interest will be deemed from sources within the Contracting... | |
 | United States. Internal Revenue Service - 1977
...resident of one of the Contracting States) has a permanent establishment in one of the Contracting States ished products made from fabrics and similar materials Lumber and wood products, except furniture borne by such permanent establishment, or (b) If the person paying the interest is a resident of one... | |
 | Hans Jörg Geiser, Pamela Alleyne, Carroll Gajraj - 1976 - 298 pages
...resident of a Schedule 1 State or a Schedule 2 State or not, has in a State a permanent establishment in connection with which the indebtedness, on which...interest is paid, was incurred, and such interest is borne by such permanent establishment, then such interest shall be deemed to arise in the State in... | |
 | Pompiliu Verzariu, Jay A. Burgess - 1977 - 110 pages
...resident of one of the Contracting States) has a permanent establishment in one of the Contracting States in connection with which the indebtedness on which...interest is paid was incurred and such interest is borne by such permanent establishment, or (b) If the person paying the interest is a resident of one... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1977 - 520 pages
...paragraph (2) also provides that if the person paying the interest is a resident of a Contracting State and has a permanent establishment in a State other than a Contracting State in connection with which in the indebtedness on which the interest is paid was incurred and such interest is paid to a resident... | |
 | United States. Congress. Joint Committee on Taxation - 1981 - 34 pages
...has a permanent establishment (Article 5) or a fixed base (Article 14) in one of the treaty countries in connection with which the indebtedness on which the interest is paid was incurred and the interest is borne by the permanent establishment or fixed base then the interest will be sourced... | |
| |
Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment... 
