BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting State unless the enterprise carries 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 Contracting State but only so much of them as is directly or indirectly attributable to that permanent establishment. The provisions of this paragraph shall, however, not apply if the enterprise proves that the above activities could not have been undertaken by the permanent establishment or have no relation with the permanent establishment.
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Samples: Double Taxation Agreement, www.incometaxindia.gov.in, Agreement
BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting 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 Contracting State but only so much of them as is directly or indirectly attributable to that permanent establishment. The provisions of this paragraph shall, however, not apply if the enterprise proves that the above activities could not have been undertaken by the permanent establishment or have no relation with are derived within such other Contracting State from sales of goods or merchandise of the same kind as those sold, or from other business transactions of the same kind as those effected, through the permanent establishment.
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Samples: Taxation Avoidance Agreement, bir-cdn.bir.gov.ph, internationaltaxtreaty.com
BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting 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 Contracting State but only so much of them as is directly or indirectly attributable to that permanent establishment. The provisions of this paragraph shall, however, not apply if the enterprise proves that the above activities could are not have been undertaken by the permanent establishment or have no relation with the permanent establishment.
Appears in 3 contracts
Samples: Agreement, Taxation Avoidance Agreement, Agreement
BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting 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 Contracting State but only so much of them as is directly or indirectly attributable to that permanent establishment. The provisions , sales in that other State of this paragraph shall, however, not apply if goods or merchandise of the enterprise proves same or similar kind as those sold through that the above activities could not have been undertaken by the permanent establishment or have no relation with 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: internationaltaxtreaty.com
BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting 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 Contracting State State, but only so much of them as is directly or indirectly are attributable to that permanent establishment. The provisions of this paragraph shall, however, not apply if the enterprise proves that the above activities could not have been undertaken by the permanent establishment or have no relation with are derived within such other Contracting State from sales of goods or merchandise of the same kind as those sold, or from other business transactions of the same kind as those effected, through the permanent establishment.
Appears in 1 contract
Samples: Agreement