S.L. 123.178 · Double Taxation Relief (Taxes On Income) (S.L. 123.178)
S.L. 123.178 Art. 3
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 5
PERMANENT ESTABLISHMENT