TMI BlogBusiness profitsX X X X Extracts X X X X X X X X Extracts X X X X ..... 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 a Contracting State carries on business in the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph (2) shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary ; the methods of apportionment adopted ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2/2007 dated 28/11/2007 Income tax before it was read as, "In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the 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." ..... X X X X Extracts X X X X X X X X Extracts X X X X
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