S.L. 123.47 · sl/123.47 (S.L. 123.47)
S.L. 123.47 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