TMI BlogBusiness profitsX X X X Extracts X X X X X X X X Extracts X X X X ..... se may be taxed in the other State but only so much of them as is attributable to (a) that permanent establishment; (b) sales in that other State of goods or merchandise of the same or similar kind as those sold through that permanent establishment; or (c) other business activities carried on in that other State of the same or similar kind as those effected through that permanent establishment. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ted or elsewhere, subject to the limitations of the taxation laws of that State : Provided that where the law of the State in which the permanent establishment is situated imposes a restriction on the amount of the executive and general administrative expenses which may be allowed, and that restriction is relaxed or overridden by any Convention or Agreement between that State and a third State ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oyalties, fees or other similar payments in return for the use of patents or other rights, or by way of commission or other charges for specific services performed or for management, or, except in the case of a banking enterprise, by way of interest on moneys lent to the permanent establishment. Likewise, no account shall be taken, in the determination of the profits of a permanent establishment, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles laid down in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchan ..... X X X X Extracts X X X X X X X X Extracts X X X X
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