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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... "
Tax Conventions with Belgium, Finland, Trinidad and Tobago, and the ... - Page 81
by United States. Congress. Senate. Committee on Foreign Relations - 1971 - 177 pages
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Internal Revenue Cumulative Bulletin

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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Internal Revenue Cumulative Bulletin

United States. Internal Revenue Service - 1979
...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...
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Code of Federal Regulations: Containing a Codification of Documents of ...

1970
...Convention (Including Article 22). ARTICLE 4 — PERMANENT ESTARLISHMENT (1) For the purposes 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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The Code of Federal Regulations of the United States of America

1971
...Convention (including Article 22) . ARTICLE 4 — PERMANENT ESTABLISHMENT (1) For the purposes 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...
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The Code of Federal Regulations of the United States of America

1973
...Article 22). ABTICLE 4 — PERMANENT ESTABLISHMENT (1) For the purposes of this Convention, the terra "permanent establishment" means a fixed place of business...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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Legal Problems of Caribbean Integration: A Study on the Legal Aspects of Caricom

Hans Jörg Geiser, Pamela Alleyne, Carroll Gajraj - 1976 - 275 pages
...effective management is situated. Article 5 Permanent Establishment \. For the purposes of this Agreement, the term "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"...
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Joint Venture Agreements in Romania: Background for Implementation, Volume 57

Pompiliu Verzariu, Jay A. Burgess - 1977 - 98 pages
...out the provisions of this Convention. ABTICLE 5 Permanent Establishment (1) For the purpose of this Convention, the term "permanent establishment" means a fixed place of business through which the business of a resident of one of the Contracting States is wholly or partly carried on. (2) The...
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Tax Treaties: Hearing Before the Committee on Foreign Relations, United ...

United States. Congress. Senate. Committee on Foreign Relations - 1982 - 515 pages
...9l2 of the Code. Article V. PERMANENT ESTABLISHMENT Paragraph l provides that for the purposes of the Convention the term "permanent establishment" means a fixed place of business through which the business of a resident of a Contracting State is wholly or partly carried on. Article V does not...
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Congressional Serial Set, Issue 13615

1987
...residents of the firstmentioned State. ARTICLE 5: PERMANENT ESTABLISHMENT 1. For the purposes of this Convention, the term "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...
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European Yearbook

P. Drillien, Euye - 1984 - 863 pages
...situated in the other Contracting State, may be taxed in that other State. 2. For the purposes of this Convention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 3. The term "permanent establishment"...
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