2.It is hereby declared— (a) that the arrangements specified in...
Article 5 Permanent establishment
1.For the purposes of this Agreement, the term “permanent establishment”...
2.The term “permanent establishment” includes especially: (a) a place of...
3.A building site or construction or installation project constitutes a...
5.Notwithstanding the preceding provisions of this Article, the term “permanent...
6.Notwithstanding the provisions of paragraphs (1) and (2) of this...
2.Subject to the provisions of paragraph (3) of this Article,...
3.In determining the profits of a permanent establishment, there shall...
4.No profits shall be attributed to a permanent establishment by...
5.For the purposes of the preceding paragraphs, the profits to...
6.Where profits include items of income or capital gains which...
2.However, such interest may also be taxed in the territory...
3.The term “interest” as used in this Article means income...
5.Where, by reason of a special relationship between the payer...
8.Notwithstanding the provisions of paragraph (2) of this Article, interest...
9.For the purposes of paragraph (8)(b) of this Article the...
1.Royalties arising in a territory and paid to a resident...
2.However, those royalties may also be taxed in the territory...
3.The term “royalties” as used in this Article means payments...
4.The provisions of paragraph (1) and (2) of this Article...
6.Where, by reason of a special relationship between the payer...
1.Citizens or nationals of a territory shall not be subjected...
2.A legal person, partnership or association deriving its status as...
3.The taxation on a permanent establishment which an enterprise of...
4.Except where the provisions of paragraph (1) of Article 9,...
5.Enterprises of a territory, the capital of which is wholly...
6.Nothing contained in this Article shall be construed as obliging...
7.The provisions of this Article shall apply to the taxes...