 | Joseph Isenbergh - 2006 - 806 pages
...of a "permanent establishment" in the US Model Treaty is in Article 5(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 onJ9 The term "fixed place of business" in... | |
 | Radhakishan Rawal - 2006 - 551 pages
...is wider as compared to Article 5(1) of the DTAA, which reads as follows: "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". The definition under section 92F(iiia)... | |
 | Bogdan Leonidovich Zimnenko - 2007 - 441 pages
...State through a permanent establishment situated therein". In turn, in Article 5 of the said treaty the term "permanent establishment" means a fixed place of business through which a resident of a Contracting State, whether or not a legal entity, carries on business activity in the other Contracting... | |
 | 1973 - 444 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 branch;... | |
 | 1970 - 442 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 branch;... | |
 | 1976 - 426 pages
...American enterprise operates in Norway through a "permanent establishment" (Article 4), defined as "a fixed place of business through which a resident...States engages in industrial or commercial activity." If so, then all "industrial and commercial profits" allocable to the permanent establishment in Norway... | |
 | 2001 - 596 pages
...supersede the provisions of this Article. Article 9 Permanent Establishment (1) For purposes of this Convention, the term "permanent establishment" means...fixed place of business through which a resident of a Contracting State engages in industrial or commercial activity. (2) The term "fixed place of business"... | |
 | 416 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"... | |
 | 436 pages
...of effective management is situated. Article 5 Permanent Establishment l. 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"... | |
 | 536 pages
...under the provisions of this Convention. 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 of a Contracting State is wholly or partly carried on. 2. The term "permanent... | |
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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... 
