Rechtsbibliothek und Fallanalyse · Österreich · Belgien · Europäische Union
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S.L. 123.178 · Double Taxation Relief (Taxes On Income) (S.L. 123.178)

S.L. 123.178 Art. 6

In KraftAmtlicher Text

An enterprise of a Contracting State shall not be deemed to have a permanent establishment in the other Contracting State merely because it carries on business in that other Contracting 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. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph.