 | United States. Internal Revenue Service - 1976 - 624 pages
...supersede the provisions of this article. Article 9. Permanent Establishment. ( 1 ) For the purpose of this Convention, the term "permanent establishment" means a fixed place of business through which industrial or commercial activity is carried on. (2) The term "fixed place of business" includes but... | |
 | 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... | |
 | United States. Internal Revenue Service - 1979 - 644 pages
...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... | |
 | 1970 - 448 pages
...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;... | |
 | 1971 - 432 pages
...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... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1971 - 792 pages
...definition found in the Income Tax Convention between the United States and the Netherlands. As so denned, the term "permanent establishment" means a fixed place of business through which a decedent was engaged in trade or business. This includes a decedent's interest in a partnership or... | |
 | 1973 - 436 pages
...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;... | |
 | Hans Jörg Geiser, Pamela Alleyne, Carroll Gajraj - 1976 - 298 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"... | |
 | Pompiliu Verzariu, Jay A. Burgess - 1977 - 110 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... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1982 - 532 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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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... 
