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....ity that is treated as a body corporate for tax purposes; (c) the term "enterprise" applies to the carrying on of any business; (d) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State; ....

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....performance of professional services and of other activities of an independent character. (i) the term "recognised pension fund" of a State means an entity or arrangement established in that State that is treated as a separate person under the taxation laws of that State and: (i) that is established and operated exclusively or almost exclusively to administer or provide retiremen....