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Spain

Category: Agreements Double Taxation Agreements With Different Countries

there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under … a resident of the Contracting State with which his personal and economic relations arc closer (centre of vital interests.)b. If the Contracting State in which he has his centre of vital interests cannot be determined, or if


Sri Lanka

Category: Agreements Double Taxation Agreements With Different Countries

there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under … be a resident of the State with which his personal and economic relations are closer (centre of vital interests);b. if the State in which he has his centre of vital in terests cannot be determined, or if


Tanzania

Category: Agreements Double Taxation Agreements With Different Countries

there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under … with which his personal and economic relations are closer (hereinafter referred to as his " centre of vital interests ");b. If the Contracting State in which he has his centre of vital interests cannot be determined, or


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Zambia

Category: Agreements Double Taxation Agreements With Different Countries

with which his personal and economic relations are closer (hereinafter referred to as his " centre of vital interest ");b. If the Contracting State in which he has his centre of vital interests cannot be determined, or … there shall in each Contracting State be attributed to the permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under


Thailand

Category: Agreements Double Taxation Agreements With Different Countries

in each Contracting State be attributed to that permanent establishment the income or profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under … with which his personal and economic relations are closer (hereinafter referred to as his " centre of vital interests ");b. If the Contracting State in which he has his centre of vital interests cannot be determined, or


Trinidad And Tobago

Category: Agreements Double Taxation Agreements With Different Countries

there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under … be a resident of the State with which his personal and economic relations are closer ("centre of vital interests");b. if the State in which he has his centre of vital interests cannot be determined, or if he


Turkey

Category: Agreements Double Taxation Agreements With Different Countries

there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under … be a resident of the State with which his personal and economic relations are closer (centre of vital interests);b. if the State in which he has his centre of vital interests cannot be determined, or if he


Turkmenistan

Category: Agreements Double Taxation Agreements With Different Countries

there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under … be a resident of the State with which his personal and economic relations are closer (centre of vital interests);b. if the State in which he has his centre of vital interests cannot be determined, or if he


Ukraine

Category: Agreements Double Taxation Agreements With Different Countries

there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under … be a resident of the State with which his personal and economic relations are closer (centre of vital interests);b. if the Contracting State in which he has his centre of vital interests cannot be determined, or if


Union Of Soviet Socialist Republics

Category: Agreements Double Taxation Agreements With Different Countries

the taxes referred to in paragraph 1.3. Taxes mentioned in this article shall not include any penalty or interest imposed by either Contracting State relating to the taxes covered by this Agreement.Article 3GENERAL DEFINITIONS1. In this Agreement, … there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate resident engaged in the same or similar activities under


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