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S.L. 123.104 · Double Taxation Relief On Taxes On (S.L. 123.104)

S.L. 123.104 Art. 5person - other - is acting on State an shall be any activities of such person a fixed a permanent

In KraftAmtlicher Text

Notwithstanding the provisions of paragraphs 1 and 2 where a than an agent of an independent status to whom paragraph 8 applies behalf of an enterprise and has, and habitually exercises, in a Contracting authority to conclude contracts in the name of the enterprise, that enterprise deemed to have a permanent establishment in that State in respect of which that person undertakes for the enterprise, unless the activities are limited to those mentioned in paragraph 4 which, if exercised through place of business, would not make this fixed place of business establishment under the provisions of that paragraph.