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... or (b) the same persons participate directly or indirect1y in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State, and in either case conditions are made or imposed between the two enterprises in their comm...
分类:综合税收政策 时间:20000101
... State. 2. The term "professional services" includes especial1y independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers,architects, dentists and accountants. Articl...
分类:综合税收政策 时间:20000101
...be deemed not to include: (a) the use of facilities sole1y for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the pu...
分类:综合税收政策 时间:20000101
... the profits of an enterprise of that Contracting State and taxes according1y profits on which an enterprise of the other Contracting State has been charged to tax in that other Contracting State, and the profits so included are profits which would have accrued to the enterprise of the first-menti...
分类:综合税收政策 时间:20000101