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Bulgaria
Category: Agreements Double Taxation Agreements With Different Countries
be a resident of the State with which his personal and economic relations are closer (centre of vital interest);b. if the Contracting State in which he has his centre of vital interest cannot be determined, the competent … 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
Germany
Category: Agreements Double Taxation Agreements With Different Countries
year;2. the term "tax" means German tax or Indian tax as the context requires but shall not include interest or penalty imposed in relation to such taxes.3. As regards the application of this Agreement by a Contracting … 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
Indonesia
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
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Ireland
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
Israel
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
Italy
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
Kazakstan
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
Kenya
Category: Agreements Double Taxation Agreements With Different Countries
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 … State 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
Malta
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 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
Mongolia
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
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