TaxTMI 
TaxTMI 
Anti-abuse Rule for Permanent Establishments Situated in Third Jurisdictions
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....o a Covered Tax Agreement derives income from the other Contracting Jurisdiction and the first-mentioned Contracting Jurisdiction treats such income as attributable to a permanent establishment of the enterprise situated in a third jurisdiction; and b) the profits attributable to that permanent establishment are exempt from tax in the first-mentioned Contracting Jurisdiction, the benef....
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....manent establishment (other than the business of making, managing or simply holding investments for the enterprise's own account, unless these activities are banking, insurance or securities activities carried on by a bank, insurance enterprise or registered securities dealer, respectively). 3. If benefits under a Covered Tax Agreement are denied pursuant to paragraph 1 with respect to an item ....
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....ns of a Covered Tax Agreement that deny or limit benefits that would otherwise be granted to an enterprise of a Contracting Jurisdiction which derives income from the other Contracting Jurisdiction that is attributable to a permanent establishment of the enterprise situated in a third jurisdiction. 5. A Party may reserve the right: a) for the entirety of this Article not to apply to it....