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true or falce. 1. according to the Commentary on Article 4 the place of effective management of an entity is the place where key management
true or falce.
1. according to the Commentary on Article 4 the place of effective management of an entity is the place where key management and commercial recision are in substance made - the place where decision-making at the highest level on the most important issiles of mananement takes place.
2. The most common pattern, consistent with Article 7 of the OECD and UN Model Treaties, is that business income is generally taxable by a country only if the taxpayer carries on business through a P in the country and the income is attributable to that PE.
3. The general rule in many countries is that income derived from personal services performed by employees, independent contractors. or professionals has its source in the country where these services are performed.
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