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TMI BlogBusiness profitsX X X X Extracts X X X X X X X X Extracts X X X X ..... foresaid, the profits of the enter price may be taxed in the other State but only so much of them as is directly or indirectly attributable to that permanent establishment. 2. Where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establishment situated therein, the profits which that permanent establishment might be expected to make if it ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... treated for the purpose of paragraph 1 of this Article as being the profits indirectly attributable to that permanent establishment. 4. Insofar as it has been customary in a Contracting State according to its law 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 paragraphs ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ting State in which the permanent establishment is situated. 6. Where the law of the Contracting State in which the permanent establishment is situated imposes a restriction on the amount of the executive and general administrative expenses which may be allowed, and the restriction it relaxed or overridden by any Convention between that Contracting State and a third State which is a member of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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, to 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 monies lent to the permanent establishment; nor shall account be taken in the determination of the profits of a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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