Rechtsbibliothek und Fallanalyse · Österreich · Belgien · Europäische Union
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S.L. 123.64 · Double Taxation Relief On Taxes On (S.L. 123.64)

S.L. 123.64 Art. 5to whom enterprise of a permanent an authority to activities are first-mentioned delivers in the first- or for the it or have a

In KraftAmtlicher Text

Where a person - other than an agent of an independent status paragraph 6 applies - is acting in a Contracting State, on behalf of the the other Contracting State, the enterprise shall be deemed to have establishment in the first-mentioned Contracting State, if such person:

(a) has and habitually exercises in the first-mentioned State, conclude contracts on behalf of the enterprise, unless his limited to the purchase of goods or merchandise for the enterprise;

(b) has no such authority, but habitually maintains in the State a stock of goods or merchandise from which he regularly goods or merchandise on behalf of the enterprise;

(c) has no such authority, but habitually secures orders mentioned State wholly or almost wholly for the enterprise enterprise and other enterprises which are controlled by controlling interest in it.