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ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡΙΛΙΟΥ
1984
fronI one or n;ore permanent establishment whioh such
corporation has
ίη
the United states, they shal1 be deemed
to be from sources
within
the United states.
425
(2) InteI'est shall be treated
βθ
income frona sources wi thin
a Contracting State only
ί!
paid by such Contracting State,
a political subdivision
οτ
a local authority thereof, or by
a resident
ο!
that Contracting 5tate. Notwithstanding the
preoeding sentence, and except for interest described
ίη
paragraph 7(0)
ο!
Article 13 (Interest) whioh shall be
deemed to be from sources within the United Statees
(a) If the person paying the interest (whether or
not such person is a resident
ο!
a Contracting State)
has a permanent estab1ishment in a Contracting State
Ιη
connection with which tbe indebtedness
οη
which the
lnterest is paid "as lncurred, and such 1nterest 18
borne
by
such permanent establiehment; or
(b) If the person paying the interest 1s a resident
of a Contracting State and has a permanent establishment
1η
a State (other than a Contracting State)
ίη
connection
with which the indebtedness
οη
wbioh the 1nterest is
pald was incurred, and suoh 1nterest 1s borne bl 8uch
pernIanent establi shment 8uch interest shal1 be deerned
to be frorn eourcee within the State
ίη
which the
perrnsnent establishment is situated.
(3)
Royalties described
ίη
paragraph (2)
ο!
Artic1e 14
(Royalties) for the use of,
οτ
the
ri~ht
to use, property or
rights described
ίη
such paragraph sha11 be treated
βθ
income from sources within a Contracting State only to the
extent
that such royalties are for the
υΒθ
of, or the right
to use, such property
οτ
rights within that Contracting
state.
(4)
Income from real property (including royalties),
described
ίη
Artic1e 15 (Income from Real Froperty), sha11
be treated
βθ
income from sources within a Contracting State
only if such property i8 s1tuated
ίη
that Contracting State.
(5)
Income from the rental
ο!
tangible personal (movable)
property shall be treated
βθ
income from sources within a
Contracting state only 1f such property is used
1η
that
Contracting State.