Commission

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..... charged shall not exceed 5 per cent of the amount of the commission. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 3. The term commission as used in this Article means a payment made to a broker, a general commission agent or to any other person assimilated to such a broker or agent by the taxation law of the Contra .....

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..... the activities for which the payment is made was incurred, and such commission is borne by such permanent establishment, then such commission shall be deemed to arise in the Contracting State in which the permanent establishment is situate. 6. Where, by reason of a special relationship between the payer and the recipient or between both of them and some other person, the amount of the commission, .....

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