S.L. 123.46 · Double Taxation Relief On Taxes On (S.L. 123.46)
S.L. 123.46 Art. 8State 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