TMI BlogBusiness profitsX X X X Extracts X X X X X X X X Extracts X X X X ..... may be taxed in the other State but only so much of them as is attributable to that permanent establishment. For the purposes of this Article, where a permanent establishment takes an active part in negotiating, concluding or fulfilling contracts entered into by the enterprise, then notwithstanding that other parts of the enterprise have also participated in those transactions, there shall be a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e profits of a permanent establishment, there shall be allowed as deductions, expenses which are incurred for the purposes of business of the permanent establishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere, in accordance with the provisions of the tax laws, and subject to the limitation ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e 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 Convention, then the provisions of those Articles shall not be affected by the provisions of this Article. - - statute, statutory provisions legislation, law, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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