 | 1987 - 948 pages
...permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent, or any other agent of an independent status, where such persons are acting in the ordinary course of their business. However, when the activities... | |
 | 1990 - 100 pages
...the enterprise. The proposed treaty contains the usual provision that the agency rule will not apply if the agent is a broker, general commission agent, or any other agent of independent status acting in the ordinary course of its business. The determination whether a company... | |
 | 1990 - 84 pages
...the enterprise. The proposed treaty contains the usual provision that the agency rule will not apply if the agent is a broker, general commission agent, or any other agent of independent status acting in the ordinary course of its business. The determination whether a company... | |
 | 1992 - 858 pages
...permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent, or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which... | |
 | 1993 - 116 pages
...establishment in the other country merely because it carries on business in that other country through a broker, general commission agent, or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. The proposed treaty, however,... | |
 | 1993 - 148 pages
...usual provision that no permanent establishment will be deemed to arise based on the agent's activities if the agent is a broker, general commission agent, or any other agent of independent status acting in the ordinary course of its business. The determination whether a company... | |
 | 1993 - 26 pages
...establishment. The proposed protocol contains the usual provision that the agency rule would not apply if the agent is a broker, general commission agent, or any other agent of independent status acting in the ordinary course of its business. These provisions of the proposed... | |
 | United States. Tax Court - 1995 - 836 pages
...authority, which it exercised, to conclude contracts on behalf of petitioners, so that unless Fortress is "a broker, general commission agent, or any other agent of an independent status" within the meaning of Article 9(5), petitioners will be deemed to have US permanent establishments.... | |
 | 1995 - 76 pages
...establishment in the treaty country merely because it carries on business in the treaty country through a broker, general commission agent, or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. The UN treaty would not treat... | |
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State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 
