 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...  Internal Revenue Cumulative Bulletin - Page 401by United States. Internal Revenue Service - 1977Full view - About this book
 | Great Britain - 1963 - 1436 pages
...of one of the Contracting States controls or is controlled by a corporation which is a corporation of the other Contracting State, or which carries on...in that other Contracting State (whether through a permament establishment or otherwise), shall not of itself constitute either corporation a permanent... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1982 - 532 pages
...Paragraph 7 provides that the fact that a company which is a resident of one Contracting State either controls or is controlled by a company which is a resident of the other Contracting State, or which is a resident of any State and carries on business in that other State, does not automatically render... | |
 | 1987 - 948 pages
...the transactions between the agent and the enterprise were not made under arm's length conditions. 7. The fact that a company which is a resident of...State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either... | |
 | 1992 - 858 pages
...independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of...State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either... | |
 | Ssociation Espanola De Profesores De Der - 1996 - 506 pages
...transactions between the company and the agent are not carried out under conditions of free competition. 7. The fact that a company which is a resident of...contracting State controls or is controlled by a company that is a resident of the other contracting State, or carries out activities in the other State (whether... | |
 | Daniel Sandler - 1998 - 326 pages
...OECD Model defines a permanent establishment. It provides, in part: Article 5 Permanent establishment 7. The fact that a company which is a resident of...State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either... | |
 | Helmut Loukota, Albert J. Rädler, Josef Schuch, Franz Wassermeyer, Gerald Toifl, Christoph Urtz - 1998 - 266 pages
...independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of...or is controlled by a company which is a resident of another Contracting State, or which carries on business in such other State (whether through a permanent... | |
 | United Nations Staff - 2002 - 564 pages
...made by that agent, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of...State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either... | |
 | Pasquale Pistone - 2002 - 424 pages
...independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of...or is controlled by a company which is a resident of ANOTHER Contracting State, or which carries on business in SUCH other State (whether through a permanent... | |
 | United Nations Staff - 2002 - 440 pages
...of an independent status, provided mat such persons are acting in me ordinary course ot me<r busme&s 7 The fact that a company which is a resident of a...or is controlled by a company which is a resident of the other Contracting Stale, or which carnes or< business m mat other Stale (whether through a permanent... | |
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