S.L. 123.64 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 Contacting which carries on business in that other State (whether through establishment or otherwise), shall not of itself constitute either permanent establishment of the other.

CHAPTER III TAXATION OF INCOME Article 6

INCOME FROM IMMOVABLE PROPERTY