 | 1981 - 40 pages
...whether he is a resident or not, has in a treaty country a permanent establishment or a fixed base 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 deemed... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1982 - 532 pages
...interest will exempt interest from tax in the Contracting State in which the payor resides if the payor has a permanent establishment in a State other than...Contracting State in connection with which the indebtedness of which the interest is paid was incurred, such interest is borne by the permanent establishment and... | |
 | 1987 - 948 pages
...of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the indebtedness on which...interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed to arise in... | |
 | 1984 - 36 pages
...the two countries or not, has in one of the two countries a permanent establishment or a fixed base 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, the interest will be deemed to... | |
 | OECD - 2000 - 48 pages
...has in a State other than that of which he is a resident a permanent establishment or a fixed base in connection with which the indebtedness on which...interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed to arise in... | |
 | OECD - 2000 - 48 pages
...of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the indebtedness on which...interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed to arise in... | |
 | Pasquale Pistone - 2002 - 424 pages
...the provisions of this Article shall apply only to the lastmentioned amount. 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... | |
 | United Nations Staff - 2002 - 564 pages
...of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the indebtedness on which...interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed to arise in... | |
 | Dániel Deák - 2003 - 486 pages
...Netherlands, the United Kingdom and the United States, the source of interest income is not extended to a PE in connection with which the indebtedness on which...interest is paid was incurred and such interest is borne by that PE. This is to shield from Hungarian tax the interest that is paid from Hungary, taxable... | |
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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... 
