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 : (a) that permanent establishment, and (b) sales of goods and merchandise of the same or similar kind as those sold, or from other business activities of the same or similar kind as those effected, through that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterpr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cordance with the principles laid down in this Article. 3. In the determination of the profits of a permanent establishment, there shall be allowed those deductible expenses which are incurred for the purposes of the business of the permanent establishment, including executive and general administrative expenses, whether incurred in the State in which the permanent establishment is situated or e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ise than towards reimbursement of actual expenses), by the permanent establishment to the head office of the enterprise or any of its other offices, by way of royalties, fees or other similar payments in return for the use of patents, know-how 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, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment, shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Agreement, then the provisions of those ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
