With reference to Articles 5, 7 and 9. Only those profits may be attributed to a building site, construction, installation, erection or assembly project in the Contracting State in which the building site, construction, installation, erection or assembly project is located which result from the activity of the building site, construction, installation, erection or assembly project itself. This means that in particula a) profits which arise from a delivery of goods made. whether in connection with this activity or independently of it, by the principal permanent establishment or another permanent establishment of the enterprise or a third party shall not be attributed to the building site, construction, installation, erection or assembly project; b) profits arising from planning, project work, design or research as well as technical services which a resident of one Contracting State performs for the building site, construction, installation, erection or assembly project located in the other Contracting State shall, so far as these activities are performed outside the other Contracting State, not be attributed to that building site, construction, installation erection or assembly project.
Appears in 5 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
