S.L. 123.147 · sl/123.147 (S.L. 123.147)
S.L. 123.147 Art. 7State controls State, or a permanent company a
The fact that a company which is a resident of a Contracting or is controlled by a company which is a resident of the other Contracting which carries on business in that other State (whether through establishment or otherwise), shall not of itself constitute either permanent establishment of the other.
Article 6 INCOME FROM IMMOVABLE PROPERTY