S.L. 123.123 · Double Taxation Relief On Taxes On (S.L. 123.123)
S.L. 123.123 Art. 7controls or State, or that or company
The fact that a company that is a resident of a Contracting State is controlled by a company that is a resident of the other Contracting carries on business in that other State (whether through a permanent establishment otherwise), shall not be taken into account in determining whether either has a permanent establishment in that other State.
Article 6 INCOME FROM REAL (IMMOVABLE) PROPERTY