BUSINESS PROFIT Sample Clauses

BUSINESS PROFIT. 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 Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise 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. 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 it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise 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 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. However, no such deduction shall be allowed in respect of amounts, if any, paid (otherwise 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 or other rights, or by way of commission, 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, for amounts charged (otherwise 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 or other rights, or by way of com...

BUSINESS PROFIT. 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 Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise 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. 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 it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise 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 general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 5. Where profits include items of income which are dealt with separately in other Articles of this Agreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFIT. 1. The profit of an entrepreneur of a Contracting State shall be taxed only by that Contracting State. If the entrepreneur also operates through a permanent establishment in another contracting state, the part of the profit that can be attributed to the permanent establishment may be taxed there. 2. Subject to paragraph 3, the contracting states shall consider as the profit attributable to a permanent establishment the profit which the permanent establishment could be expected to obtain, operating independently under the same or similar conditions in the same or the same field of activity as the entrepreneur of the other contracting state, whose permanent establishment it is. 3. Considering the profit attributable to the permanent establishment, management and administrative expenses and other expenses related to the business activities of the permanent establishment may be deducted from the income, regardless of whether they occurred in the country of the permanent establishment or elsewhere. 4. If in a contracting state, taking into account the profit attributable to a permanent place of business, the total profit of an enterprise is usually distributed proportionally between the parts of the enterprise, paragraph 2 does not conflict with the right of the contracting state to use the specified method if the result of the application of the method is in accordance with the principles of this article. 5. Taking into account the profit discussed in the previous paragraphs, the same method is applied every year, unless there is a sufficient reason to change it. 6. If the profit includes income covered by other articles of the agreement, other relevant provisions shall apply.

BUSINESS PROFIT. 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 Contracting State through a permanent establishment situated in that other State. If the enterprise carries on business in that manner, the profits of the enterprise may be 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 it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In the determination of the profits of a permanent establishment, there shall be allowed as deductions, expenses of the enterprise, being expenses which are incurred for the purposes of the permanent establishment (including executive and general administrative expenses so incurred) whether incurred in the Contracting State in which the permanent establishment is situated or elsewhere, except a deduction for amounts paid to its head office or any other office of the resident by way of royalties, fees or other similar payment in return of the use of patents or other rights, or by way of commission, for specific services performed or for management, or by way of interest on money lent to the permanent establishment. 4. Insofar as 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 method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. Where information which has one of the Contracting States or information which is easy to get in conformity with paragraphs 3 and 4 of this Article is not enough to determine the profits or the expenses of a permanent establishment, then the profits will be determined in conformity with ...