S.L. 123.43 · Double Taxation Relief On Taxes On (S.L. 123.43)
S.L. 123.43 Art. 7controls or State or a permanent company a
The fact that a company which is a resident of a Contractig State 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 permanent establishment of the other.
ARTICLE 7
Income from Immovable Property