 | 1987 - 948 pages
...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... | |
 | P. Drillien, Euye - 1984 - 892 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"... | |
 | 1992 - 858 pages
...(Interest), and Article 12 (Royalties). 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"... | |
 | 1993 - 72 pages
...under Article 6 (Business Profits). In general, under the proposed treaty, a permanent establishment is a fixed place of business through which a resident of one of the treaty countries engages in business in the other treaty country. For this purpose no distinction is... | |
 | Helmut Loukota, Albert J. Rädler, Josef Schuch, Franz Wassermeyer, Gerald Toifl, Christoph Urtz - 1998 - 266 pages
...of effective management is situated. 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"... | |
 | Pasquale Pistone - 2002 - 424 pages
...Permanent establishment Article 5 Multilateral Tax Treaty Permanent establishment 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"... | |
 | United Nations Staff - 2002 - 564 pages
...Agreement to such person. Article 5 Permanent Establishment 1 . For the purposes of this Agreement, the term "permanent" establishment" means a fixed place of business through which the business of an enterprise of a Contracting State is wholly or partly carried on. 162 2. The term... | |
 | World Trade Organization - 2004 - 600 pages
...Convention is defined in its Article 5;126 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"... | |
 | Guglielmo Maisto - 2005 - 375 pages
...consideration. 28 Article 5 contains the definition of a PE and reads as follows: (1) For the purpose 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) A building site or construction... | |
 | Deloitte Touche Tohmatsu (Firm) - 2005 - 430 pages
...latter state, and only to the extent that the profits are attributable to the permanent establishment. The term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. Generally speaking, it includes: •... | |
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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... 
