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" 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... "
Internal Revenue Cumulative Bulletin - Page 414
by United States. Internal Revenue Service - 1977
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The Code of Federal Regulations of the United States of America

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...
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The Code of Federal Regulations of the United States of America

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...
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Code of Federal Regulations: Containing a Codification of Documents of ...

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...
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Internal Revenue Bulletin: Cumulative bulletin

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...
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Internal Revenue Cumulative Bulletin

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...
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Internal Revenue Cumulative Bulletin, Issue 2

United States. Internal Revenue Service - 1979 - 644 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...
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Legal Problems of Caribbean Integration: A Study on the Legal Aspects of Caricom

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...
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Tax Treaties with the United Kingdom, the Republic of Korea, and the ...

United States. Congress. Senate. Committee on Foreign Relations - 1977 - 520 pages
...interest (whether or not such person is a resident of a Contracting State) has a permanent etablishmemt 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...
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Joint Venture Agreements in Romania: Background for Implementation, Volume 57

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...
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Tax Treaties: Hearing Before the Committee on Foreign Relations, United ...

United States. Congress. Senate. Committee on Foreign Relations - 1982 - 532 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 as a deduction by the permanent establishment, the interest will be deemed to be from sources...
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