 | United States. Internal Revenue Service - Internal revenue - 1977
...enterprise of which it is a permanent establishment, of goods or merchandise for the enterprise. (5) Where / ( R Rd äӲE q GZ ʡ,# { 6F , S : ($[B .=; 0 this Convention, the provisions of those articles shall, except as otherwise provided therein, supersede... | |
 | United States. Internal Revenue Service - Internal revenue - 1976 - 624 pages
...income were accounted for through such permanent establishment. (7) Where industrial or commercial profits include items of income which are dealt with separately in other articles of this Convention, the provisions of those articles shall, except as otherwise provided therein, supersede... | |
 | United States. Internal Revenue Service - Internal revenue - 1979 - 644 pages
...income were accounted for through such permanent establishment. (7) Where industrial or commercial profits include items of income which are dealt with separately in other articles of this Convention, the provisions of those articles shall, except as otherwise provided therein, supersede... | |
 | Hans Jörg Geiser, Pamela Alleyne, Carroll Gajraj - Law - 1976 - 298 pages
...services or remuneration for personal (including professional) services. 9. Where industrial or commercial profits include items of income which are dealt with separately in other Articles of this Agreement, the provisions of those Articles shall, except as otherwise provided therein, supersede... | |
 | Pompiliu Verzariu, Jay A. Burgess - Corporations, Foreign - 1977 - 110 pages
...income were accounted for through such permanent establishment. (8) Where industrial or commercial profits include items of income which are dealt with separately in other articles of this convention, the provisions of those articles shall, except as otherwise provided therein, supersede... | |
 | United States. Congress. Joint Committee on Taxation - Double taxation - 1979 - 26 pages
...on its purchasing activities. Where business profits include items of income which are dealt witli separately in other articles of the treaty, those...will govern the treatment of those items of income. Article 8. Shipping and air transport The proposed treaty provides that income which is derived by... | |
 | United States. Congress. Joint Committee on Taxation - Double taxation - 1981 - 34 pages
...reason of the purchase of merchandise by the permanent establishment for the account of the enterprise. Thus, where a permanent establishment purchases goods...will govern the treatment of those items of income. Thus, for example, certain film rentals are taxed under the provisions of Article 12 (Royalties), and... | |
 | United States. Congress. Joint Committee on Taxation - Double taxation - 1981 - 38 pages
...be treated as business profits subject to Argentine tax. (See Article 5 (Permanent Establishment).) Where business profits include items of income which...will govern the treatment of those items of income. Thus, for example, film rentals are taxed under thp provisions of Article 12 (Royalties), and not as... | |
 | Double taxation - 1981 - 58 pages
...headquarters office for the company without being taxed in the country on profits generated by that activity. Where business profits include items of income which...will govern the treatment of those items of income. Thus, for example, film rentals are taxed under the provisions of Article XII (Royalties), and not... | |
 | Double taxation - 1981 - 40 pages
...the permanent establishment with respect to its other activities will not be increased by a profits element on its purchasing activities. Where business...articles of the treaty, those other articles, and not the business profits article, will govern the treatment of those items of income. Unlike the US model... | |
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For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 
