S.L. 123.185 · Double Taxation Relief (Taxes On Income) (S.L. 123.185)
S.L. 123.185 ст. 8
The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.
Article 6
INCOME FROM IMMOVABLE PROPERTY