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TMI BlogBusiness profitsX X X X Extracts X X X X X X X X Extracts X X X X ..... . If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is 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, there shall in each Contracting State be attributed to tha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ce with the principles laid down in this Article. 4. (a) In the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses of the enterprise which are incurred for the purposes of the permanent establishment, including only those executive and general administrative expenses incurred, whether in the State in which the permanent establishment is situate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at Convention and, if the competent authority of the other Contracting State so requests, the provisions of this sub-paragraph shall be amended by protocol to reflect such terms. (b) However, no such deduction shall be allowed in respect of amounts, if any, paid (otherwise than towards reimbursement of actual expenses) by the permanent establishment to the head office of the enterprise or any of i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... terprise, by way of interest on monies lent to the head office of the enterprise or any of its other offices. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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