S.L. 123.38 · sl/123.38 (S.L. 123.38)
S.L. 123.38 Art. 8State controls State, or a permanent a permanent
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 Contracting which carries on business in that other State (whether through establishment or otherwise) shall not of itself constitute either company establishment of the other.
ARTICLE 6
Income from Immovable Property