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United States Of America

Category: Agreements Double Taxation Agreements With Different Countries

on behalf of that enterprise and the transactions between the agent and the enterprise are not made under arm's-length conditions, he shall not be considered an agent of independent status within the meaning of this paragraph.6. The


Greece

Category: Agreements Double Taxation Agreements With Different Countries

independent enterprise engaged in the same or similar activities under the same or similar conditions and dealing at arm's length with the enterprise of which it is a permanent establishment. In any case, where the correct amount


Austria

Category: Agreements Double Taxation Agreements With Different Countries

independent enterprise engaged in the same or similar activities under the same or similar conditions and dealing at arm's length with the enterprise of which it is a permanent establishment. In any case, where the ascertainment of


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Belgium

Category: Agreements Double Taxation Agreements With Different Countries

independent enterprise engaged in the same or similar activities under the same or similar conditions and dealing at arm's length with the enterprise of which it is a permanent establishment.3.a. In the determination of the profits of


Canada

Category: Agreements Double Taxation Agreements With Different Countries

on behalf of that enterprise and the transactions between the agent and the enterprise are not made under arm's length conditions, he shall not be considered an agent of independent status within the meaning of this paragraph.6.


France

Category: Agreements Double Taxation Agreements With Different Countries

if it is shown that the transactions between the agent and the enterprise were not made under at arm's length conditions.7. The fact that a company which is a resident of one of the Contracting States controls


Malta

Category: Agreements Double Taxation Agreements With Different Countries

agent of an independent status if the transactions between the agent and the enterprise were not made under arm's length conditions.8. The fact that a company which is a resident of a Contracting State controls or is


Netherland

Category: Agreements Double Taxation Agreements With Different Countries

if it is shown that the transactions between the agent and the enterprise were not made under at arm's-length conditions.4. The fact that a company which is a resident of one of the States controls or is


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