business profits means income derived from any trade or business whether carried on by an individual, corporation or any other person, or group of persons, including the rental of tangible personal (movable) property.
business profits. Nothing in this Agreement shall affect the operation of any law of a Contracting State relating to the taxation of income or profits from any insurance business provided that if the relevant law in force in either Contracting State at the date of signature of this Agreement is amended (otherwise than in minor respects so as not to affect its general character) the States shall consult with each other with a view to agreeing to any amendment of this paragraph that may be appropriate.
business profits means income derived from any trade or business including income from the furnishing of services other than included services as defined in Article 12 (Royalties and Fees for Included Services) and including income from the rental of tangible personal property other than property described in paragraph 3(b) of Article 12 (Royalties and Fees for Included Services).
More Definitions of business profits
business profits. Industrial and Commercial Profits" or "Other Income" provisions, if any, of such treaty (i) before the first Scheduled Payment Date with respect to any such Transaction and thereafter during each third succeeding calendar year, (ii) promptly upon reasonable demand by the Guarantor, and (iii) promptly upon learning that any such form previously provided has become obsolete or incorrect.
business profits or "Industrial or Commercial Profits" provision, as the case may be, the "Interest" provision or the "Other Income" provision (if any) of the tax treaty between the United Kingdom and Australia with respect to any payment described in such provisions and received or to be received by it in connection with this Agreement and no such payment is attributable to a trade or business carried on by it through a permanent establishment in Australia. It is a non-U.S. branch of a foreign person for U.S. federal income tax purposes. Party B makes the following representations: It is an Australian resident and does not derive payments under this Agreement in part or in whole carrying on business in a country outside Australia at or through a permanent establishment or itself in that country. The Trust is a non-U.S. branch of a foreign person for U.S. federal income tax purposes.
business profits and "business lossess" do not include gains or losses of a capital nature to which Article 8 of this Taxation Code applies. Article 5 Dividends 1. Dividends which are paid by a company which is a resident of a Contracting State wholly or partly out of profits derived from sources in Area A, and which are beneficially owned by a resident of the other Contracting State, may be taxed only in that other Contracting State. 2. The term "dividends" as used in this Article means income from shares or other rights participating in profits and not relating to debt claims, as well as other income which is subjected to the same taxation treatment as income from shares by the law of the Contracting State of which the company making the distribution is a resident. Article 6 Interest 1. Interest paid by a contractor, being interest to which a resident of a Contracting State is beneficially entitled, may be taxed in that Contracting State.
business profits or “other income” article of such tax treaty;
business profits means income derived by an enterprise from the carrying on of trade or business; but does not include income in the form of rents, royalties (including rents or royalties in respect of cinematographic films or video tapes for television), fees for technical services, management charges, or remuneration or fees for providing services of technical or other personnel, interest, dividends, capital gains, remuneration for labour or personal (including professional) services or income from the operation of ships or aircraft.
business profits is defined generally in paragraph 8 to mean income derived from any trade or business. In accordance with this broad definition, the term "business profits" is understood to include income attributable to notional principal contracts and other financial instruments to the extent that the income is attributable to a trade or business of dealing in such instruments, or is otherwise related to a trade or business (as in the case of a notional principal contract entered into for the purpose of hedging currency risk arising from an active trade or business). Any other income derived from such instruments is, unless specifically covered in another article, dealt with under Article 24 (Other Income). Income earned by an enterprise from the furnishing of personal services is business profits. Thus, a consulting firm resident in one State whose employees perform services in the other State through a permanent establishment may be taxed in that other State on a net basis under Article 7, and not under Article 15 (Independent Personal Services), which applies only to individuals. The salaries of the employees would be subject to the rules of Article 16 (Dependent Personal Services). The paragraph specifies that the term "business profits" includes income derived by an enterprise from the rental of ships, aircraft, and containers, including trailers, barges and related equipment for the transport of containers if such income is not incidental to income from the operation of ships or aircraft in international traffic (in which case it would be subject to Article 8 (Shipping and Air Transport)). The inclusion of such in business profits means that such income earned by a resident of a Contacting State can taxed by the other Contracting State only if the income is attributable to a permanent establishment in that other State, and, if the income is taxable, it can taxed only on a net basis. Paragraph 9 incorporates into the Convention the rule of Code section 864(c)(6). Like the Code section on which it is based, paragraph 8 provides that any income or gain attributable to a permanent establishment or a fixed base during its existence is taxable in the Contracting State where the permanent establishment or fixed base is situated, even if the payment of that income or gain is deferred until after the permanent establishment or fixed base ceases to exist. This rule applies with respect to paragraphs 1 and 2 of Article 7 (Business Profits), paragraph 5 of Article 10 (Dividen...
business profits or "Industrial or Commercial Profits" provision, as the case may be, the "Interest" provision or the "Other Income" provision (if any) of the Specified Treaty with respect to any payment described in such provisions and received or to be received by it in connection with this Agreement and no such payment is attributable to a trade or business carried on by it through a permanent establishment in the Specified Jurisdiction. If such representation applies: