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Double Taxation and its Avoidance 126
Legal Framework of Doable Tax Treaties 2757
Interpretation of Double Tax Treaties 5888
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according activities alienation apply Article m.no attributable beneficial owner BFH BStBl capital gains clause Conformity and divergence contracting corporate corresponding rule definition distributive rules domestic law double taxation DTC MC rule DTC with Italy DTC with Switzerland DTC with USA effective management Egypt enterprise enterprise's EStG exemption Explanatory notes expressly Federal Republic fixed base FProt German Germany's DTC immovable property independent personal services Indonesia infra Art infra m.no inter-company dividends interest interpretation items of income Ivory Coast Liberia Luxembourg Malaysia MC Comm MC Commentary meaning of Art Model Conventions Netherlands OECD MC paid Pakistan paragraph payments percent permanent establishment place of business place of effective place of management principle Prot provisions reference Regarding Art remuneration residence restriction right to tax royalties shares ships or aircraft supra Art supra m.no suspension clauses Sweden Synoptic Table Table re Art tax law tax treaties taxable term tion withholding tax Zambia Zimbabwe