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432
ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡΙΛΙΟΥ
1984 ,
that resident, unless the activities of such person 8re
limited to those mentioned in paragraph
(3)
which,
if
exercised through
a
fixed place of business, wou1d not
aake the fixed place
ο'!
business
a
permanent establishment
\Ulder
tbe provisions
ο'!
that paragraph.
(5)
Α
resident of
a
Contract1ng State shall not be deemed
to have
a
pel"nlanent establishment
ίη
the other Contracting
State merely because such
r~sident
engages
ίη
industrial
or
conlΠlercial
activi ty
ίη
that other Contracti.ng State through
a
broker, general commission agent, or
any
other agent
ο!
an
independent status, where such broker
011
agent
is
acting in
the
ordillary course of his business.
(6)
The fact that
a
resident
ο!
a Contracting State i8
a
relatecl person
(νι1
thin the meaning
ο!
Article
11
(Related
Persons» with respect to
a
resident
ο'!
the other Contracting
State or with respect to a person who engages
ίη
industrial
or commercial activity in that other Contracting State
(whether through
a
permanent establishment or otherwise)
shal1
not be te.ken into account in deterIrIining whether that resident
of the first-mentioned Contracting State has
a
permanent
establishment in that other
Contractir~
State.
(7)
The princi}:les set i'orth in paragraphs
(1)
through
(6)
.
shall be applied in determining for the purposes of this
Convention whether there is
a
permanent establishment
ίη
a
State other than a Contracting State or whether
a
person
other than a resident
ο!
a Contracting State
has a
permanent
establishment
ίη
a
Contractlng State.
Article
10
SHIPFING
ΑΝΏ ΑΙΗ
TRANSYORT
(1) Notwithstanding Articles
8
(Business Profits) and
l6
(Gaine), income which a resident
ο'!
a Contracting State
derives from the oI1eration
ίη
international traffic
ο'!
ships
or aircraft, including gains derived fronl the sale, exchange ,
or other disposition of such
shi~s οτ
airoraft, shall be
exe~pt
from tax
by
the other Contracting State.