 | 1999 - 220 pages
...(including Article 22). ARTICLE 4 — PERMANENT ESTABLISHMENT (1) For the purposes of this Convention, the term "permanent establishment" means a fixed place...through which a resident of one of the Contracting States engaged in industrial or commercial activity. (2) The term "permanent establishment" shall include... | |
 | 1999 - 240 pages
...(including Article 22). ARTICLE 4 — PERMANENT ESTABLISHMENT (1) For the purposes of this Convention, the term "permanent establishment" means a fixed place...through which a resident of one of the Contracting States engaged in industrial or commercial activity. (2) The term "permanent establishment" shall include... | |
 | 1990 - 214 pages
...(including Article 22). ARTICLE 4— PERMANENT ESTABLISHMENT (1) For the purposes of this Convention, the term "permanent establishment" means a fixed place...through which a resident of one of the Contracting States engaged in industrial or commercial activity. (2) The term "permanent establishment" shall include... | |
 | United States. Internal Revenue Service - 1968 - 1034 pages
...(including Article 22). AKI 1 1 IK 4 PERMANENT ESTABLISHMENT (1) For the pnrposes of this Convention, the term "permanent establishment" means a fixed place...States engages in industrial or commercial activity. (2) The term "permanent establishment" shall include especially : (a) A seat of management ; (b) A... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1965 - 196 pages
...which are the subject of the present Convention. ARTICLE 3 DEFINITION OF PERMANENT ESTABLISHMENT (1) The term "permanent establishment" means a fixed place of business through which a resident or corporation of one of the Contracting States engages in trade or business. (2) The term "a fixed... | |
 | United States. Congress. Senate. Foreign Relations - 1967 - 128 pages
...modernized version of the definition found in most conventions to which the United States is a party. The term "permanent establishment" means "a fixed place of business through which a resident or corporation of one of the Contracting States engages in trade or business". Illustrations of the... | |
 | United States. Internal Revenue Service - 1971 - 816 pages
...in an independent capacity. ARTICLE 9 PERMANENT ESTABLISHMENT 1. For the purpose of this Convention, the term "permanent establishment" means a fixed place...States engages in industrial or commercial activity. 2. The term "permanent establishment" shall include especially: (a) a seat of management; (b) a branch;... | |
 | United States. Internal Revenue Service - 1979 - 644 pages
...profits and in determining the applicability of other provisions of the Convention. Under paragraph (1), the term "permanent establishment" means a fixed place of business through which industrial or commercial activity is carried on. Illustrations in paragraph (2) of a fixed place of... | |
 | United States. Internal Revenue Service - 1976 - 624 pages
...Articles 12 (Dividends), 13 (Interest), 14 (Royalties), and 16 (Capital Gains). Under paragraph (1), the term "permanent establishment" means a fixed place of business through which industrial or commercial activity is carried on. Illustrations in paragraph (2) of a fixed place of... | |
 | United States. Internal Revenue Service - 1977
...Articles 11 (Dividends), 12 (Interest), 13 (Royalties), and 14 (Capital Gains). Under paragraph ( 1 ) , the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. Illustrations in paragraph (2) of a permanent... | |
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permanent establishment' means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term 'permanent establishment... 
