Business profits

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..... may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which i .....

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..... tual expenses) by the permanent establishment to the head office of the enterprise or any of its other offices, by way of royalties, fees or other similar payments in returns for the use of patents or other rights, or 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 moneys lent to the permanent establishm .....

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..... to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an appointment as may be customary, the method of appointment adopted shall, however, be such that the result be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase .....

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