 | 1999 - 220 pages
...Convention (including Article 22). ARTICLE 4 — PERMANENT ESTABLISHMENT (1) For the purposes of this Convention, the term "permanent establishment" means...through which a resident of one of the Contracting States engaged in industrial or commercial activity. (2) The term "permanent establishment" shall include... | |
 | 1980 - 476 pages
...Convention (Including Article 22). ARTICLE 4— PERMANENT ESTABLISHMENT (1) For the purposes of this Convention, the term "permanent establishment" means...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
...Convention (including Article 22). ARTICLE 4 — PERMANENT ESTABLISHMENT (1) For the purposes of this Convention, the term "permanent establishment" means...through which a resident of one of the Contracting States engaged in industrial or commercial activity. (2) The term "permanent establishment" shall include... | |
 | 1990 - 216 pages
...this Convention (including Article 22). AÏTTŒX 4 — PsajturEiT Ear.» (1) For the purposes of tius Convention, the term 'permanent establishment" means a fixed place of business through whieb a resident of one of the Contracting States engaged m industrial or commercial activity. •... | |
 | United States. Internal Revenue Service - 1968 - 1034 pages
...Convention (including Article 22). AKI 1 1 IK 4 PERMANENT ESTABLISHMENT (1) For the pnrposes of this Convention, the term "permanent establishment" means...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. Committee on Foreign Relations - 1967 - 1444 pages
...convention. The new definition is taken from the OECD model convention except as noted below. As modified the term "permanent establishment" means "a fixed...commercial activity." Illustrations of the concept of a fixed place of business include a seat of management, a branch, an office, a factory, a workshop, a... | |
 | 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. Congress. Senate. Foreign Relations - 1968 - 80 pages
...commercial profits (as defined in the convention) of a resident or corporation of the other State. 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". The convention illustrates... | |
 | United States. Internal Revenue Service - 1971 - 816 pages
...employee or in an independent capacity. ARTICLE 9 PERMANENT ESTABLISHMENT 1. For the purpose of this Convention, the term "permanent establishment" means...States engages in industrial or commercial activity. 2. The term "permanent establishment" shall include especially: (a) a seat of management; (b) a branch;... | |
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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... 
