Where by reason of the provisions. of paragraph (1) a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the Contracting State in which its place of effective management is situated. ARTICLE V - Permanent establishment - 1. For the purposes of this Convention, the term “permanent establishment” means a fixed place of business in which the business of the enterprise is wholly or partly carried on.
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Samples: Convention for the Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
Where by reason of the provisions. of paragraph (1) , a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the Contracting State in which its place of effective management is situated.
ARTICLE V - 5 : Permanent establishment - 1. For the purposes of this Convention, the term “permanent establishment” means a fixed place of business in through which the business of the an enterprise is wholly or partly carried on.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation and the Prevention of Fiscal Evasion
Where by reason of the provisions. of paragraph (1) 1 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the Contracting State in which its place of effective management is situated.
ARTICLE V 5 - Permanent establishment - 1. For the purposes of this Convention, the term “permanent establishment” means a fixed place of business in through which the business of the enterprise is wholly or partly carried on.
Appears in 2 contracts
Samples: Agreement for Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Where by reason of the provisions. of paragraph (1) ), a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the Contracting State in which its place of effective management is situated.
ARTICLE V 5 - Permanent establishment - (1. ) For the purposes of this Convention, the term “permanent establishment” means a fixed place of business in through which the business of the enterprise is wholly or partly carried on.
Appears in 1 contract
Where by reason of the provisions. of paragraph (1) , a person person, other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the Contracting State in which its place of effective management is situated.
ARTICLE V 5 - Permanent establishment - 1. For the purposes of this Convention, the term “permanent establishment” means a fixed place of business in through which the business of the an enterprise is wholly or partly carried on.
Appears in 1 contract
Where by reason of the provisions. of paragraph (1) 1 of this Article, a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the Contracting State in which its place of effective management is situated.
ARTICLE V - 5 : Permanent establishment - 1. For the purposes of this Convention, the term “permanent establishment” means a fixed place of business in through which the business of the enterprise is wholly or partly carried onon separately or together with other persons.
Appears in 1 contract
Where by reason of the provisions. of paragraph (1) ), a person other than an individual is a resident of both the Contracting States, then it shall be deemed to be a resident of the Contracting State in which its place of effective management is situated.
ARTICLE V 5 - Permanent establishment - 1. For the purposes of this Convention, the term “permanent establishment” establishment means a fixed place of business in through which the business of the enterprise is wholly or partly carried on.
Appears in 1 contract
Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion With Mauritius
Where by reason of the provisions. of paragraph (1) ), a person other than an individual is a resident of both the Contracting States, then it shall be deemed to be a resident of the Contracting State in which its place of effective management is situated.
ARTICLE V 5 - Permanent establishment - 1. For the purposes purpose of this ConventionAgreement, the term “permanent establishment” means a fixed place of business in which the business of the enterprise is wholly or partly carried on.
Appears in 1 contract
Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion