S.L. 123.166 Art. 6an insurance be deemed if it collects related to those or insures insured by an

Notwithstanding the preceding provisions of this Article, enterprise of a Contracting State shall, except in regard to re-insurance, to have a permanent establishment in the other Contracting State premiums in the territory of that other State provided that the profits premiums are not liable to tax in the first-mentioned Contracting State risks situated therein. If such premiums are collected or such risks are agent of an independent status, paragraph 7 applies to this person.