Art III GATT and the Sample Clauses

Art III GATT and the. Allocation Rules of DTCs Situations occur where different kinds of products are subject to the same taxation or where the same kinds of products are subject to different taxation. For instance, if income from royalties can be allocated to a Permanent Es- tablishment in the source country, the income will not be subject to withhold- ing tax on royalties, cf. Art 12 in OECD MC, but subject to taxation as busi- ness profits, cf. Art 9 in OECD MC. It seems not clear whether such examples of different treatment are con- trary to Art III.
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