Common use of Business profits - 1 Clause in Contracts

Business profits - 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.

Appears in 3 contracts

Samples: Agreement for Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion

AutoNDA by SimpleDocs

Business profits - 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 establishmentestablishment ; or (b) sales in that other State of goods or merchandise of the same or similar kind as those sold through that permanent establishmentestablishment ; or or (c) other business activities carried on in that other State of the same or similar kind as those effected through that permanent establishment.

Appears in 2 contracts

Samples: Double Taxation Agreement, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion

Business profits - 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 also 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 or (c) other business activities carried on in that other State of the same or similar kind as those effected through that permanent establishment.

Appears in 2 contracts

Samples: Double Taxation Agreement, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion

Business profits - 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 establishmentestablishment ; (b) sales in that the other State of goods or merchandise of the same or similar kind as those sold through that permanent establishmentestablishment ; or (c) other business activities carried on in that the other State of the same or similar kind as those effected through that permanent establishment.

Appears in 2 contracts

Samples: Agreement for Avoidance of Double Taxation of Income, Double Taxation Avoidance Agreement

Business profits - 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 affected through that permanent establishment.

Appears in 1 contract

Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion

Business profits - 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. The provisions of sub-paragraphs (b) and (c) above shall not apply if the enterprise proves that such sales or activities are not attributable to the permanent establishment.

Appears in 1 contract

Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion

Business profits - 1. The profits of an enterprise of a Contracting State shall be taxable only in that the 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 or (c) other business activities carried on in that other State of the same or similar kind as those effected through that permanent establishment. The provisions of sub-paragraphs (b) and (c) above shall not apply if the enterprise proves that such sale or activity could not have been reasonably undertaken by the permanent establishment.

Appears in 1 contract

Samples: Agreement for Avoidance of Double Taxation of Income

AutoNDA by SimpleDocs

Business profits - 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 or has carried 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 the 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.

Appears in 1 contract

Samples: Agreement for Avoidance of Double Taxation of Income

Business profits - 1. The income or 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 income or profits of the enterprise may be taxed in the other State but only so much of them as is it attributable to 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 or (c) other business activities carried on in that other State of the same or similar kind as those effected through that permanent establishment.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

Business profits - 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 these 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.

Appears in 1 contract

Samples: Convention for the Avoidance of Double Taxation

Draft better contracts in just 5 minutes Get the weekly Law Insider newsletter packed with expert videos, webinars, ebooks, and more!