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Syria

Category: Agreements Double Taxation Agreements With Different Countries

mere purchase by that permanent establishment of goods or merchandise for the enterprise.5. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year


Spain

Category: Agreements Double Taxation Agreements With Different Countries

the activities continue for a period of more than thirty days in any twelve month period.1.2.3. Notwithstanding the preceding provisions of this Article, the term " permanent establishment " shall be deemed not to include:a. the use


South Korea

Category: Agreements Double Taxation Agreements With Different Countries

only where such site project or activities continue for a period of more than nine months.4. Notwithstanding the preceding provisions of this Article, the term " permanent establishment " shall be deemed not to include:a. the use


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Romania

Category: Agreements Double Taxation Agreements With Different Countries

or supervisory activity exceed 10 per cent. of the sale price of the machinery or equipment.1.2.3. Notwithstanding the preceding provisions of this article, the term "permanent establishment" shall be deemed not to include;a. the use of facilities


Namibia

Category: Agreements Double Taxation Agreements With Different Countries

project for a period or periods aggregating more than six months within any twelve months period.1.2.3.4. Notwithstanding the preceding provisions of this article, the term "permanent establishment" shall be deemed not to include:a. the use of facilities


Mauritius

Category: Agreements Double Taxation Agreements With Different Countries

where such site, project or supervisory activity continues for a period of more than nine months.1.2.3. Notwithstanding the preceding provisions of this Article, the term permanent establishment shall be deemed not to include:a. the use of facilities


Japan

Category: Agreements Double Taxation Agreements With Different Countries

with the exploration, exploitation or extraction of mineral oils in that Contracting State.6. Notwithstanding the provisions of the preceding paragraphs of this article, the term "permanent establishment" shall be deemed not to include:a. the use of facilities


Israel

Category: Agreements Double Taxation Agreements With Different Countries

constitute a permanent establishment only if such site, project or activity last more than six months.4. Notwithstanding the preceding provisions of this article, the term "permanent establishment" shall be deemed not to include:a. the use of facilities


Hungary

Category: Agreements Double Taxation Agreements With Different Countries

or supervisory activity exceed 10 per cent of the sale price of the machinery and equipment.3. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include:a. the use of facilities


Germany

Category: Agreements Double Taxation Agreements With Different Countries

be used in the prospecting for or extraction or exploitation of mineral oils in that State.4. Notwithstanding the preceding provisions of this article, the term "permanent establishment" shall be deemed not to include:a. the use of facilities


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