S.L. 123.3 · Double Taxation Relief On Taxes On (S.L. 123.3)
S.L. 123.3 Art. 6State 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 7 Income from Immovable Property