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Business profits

Article 7 - Agreements - Kazakstan - Kazakhstan (Kazakstan) - Article 7 - Article 7 : 1. The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other ContractingState t .....

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ct to the provisions of paragraph 3, where an enterprise of a Contracting State carries on or has carried on business in the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attribut .....

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nterprise of which it is a permanent establishment. 3. In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establishment, including executive and .....

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hment shall not be allowed a deduction for amounts paid to its head office or any of the other offices of the resident by way of royalties, fees or other similar payment in return for the use of patents or other rights, or by way of commission, for s .....

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or merchandise for the enterprise. 5. Where profits include items of income or capital gains which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this A .....

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