On July 21, 1959, France and Germany signed a bilateral income tax treaty that bears a striking resemblance to modern-day tax treaties. Its original version had an Article 4th with provisions about business profits, Articles 7th, 9th, 10 and 15 with provisions about taxing rights on capital gains, dividends, interest and royalties, and even an Article 8th about permanent establishments (PEs). In 1959, Article 8th was a single paragraph stating that a company in Germany that had a PE in France would not be liable to tax on the distribution of profits it received from its PE. It is in Article 2nd that you find the definitional aspects of PEs in that treaty. Here is the text of its Article 2(7)(d) translated to English:
