TMI BlogBusiness profitsX X X X Extracts X X X X X X X X Extracts X X X X ..... f the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment.] 2. Subject to the provisions of paragraph (3), where an enterprise of one of the Contracting States carries on business in the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d in the Contracting State in which the permanent establishment is situated or elsewhere. 4. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 5. Where the correct amount of profits attributable to a permanent establishment is incapable of determination by the taxation authority ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... shall not be affected by the provisions of this Article. 8. Nothing in this Article shall affect the operation of any law of a Contracting State relating to tax imposed on profits from insurance with non-residents provided that if the relevant law in force in either Contracting State at the date of signature of this Agreement is varied (otherwise than in minor respects so as not to affect its ge ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ther Contracting State by that resident through a permanent establishment situated therein and that share of business profits shall be attributed to that permanent establishment. -------------- Notes:- 1. Substituted vide Notification No. 74/2013 dated September 20, 2013 , before it was read as, 1. The profits of an enterprise of one of the Contracting States shall be taxab ..... X X X X Extracts X X X X X X X X Extracts X X X X
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