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2005 (10) TMI 32 - AAR - Income TaxNon-resident companies - Group provides various products to various business worldwide, by providing BIRs information to help customers improve their understanding of a prospective client or supplier - payments made by the B Ltd. for the electronic purchases of Business Information Reports (BIRs) to the applicant will be treated as part of the applicant's business profits and hence covered within the provision of article 7 of the treaty - applicant will be held as not having a PE
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