Common use of BUSINESS PROFITS Clause in Contracts

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. 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 directly or indirectly attributable to that permanent establishment.

Appears in 1 contract

Samples: Double Taxation Agreement

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BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise may also be taxed in the other State but only so much of them as is directly or indirectly attributable to that permanent establishment.to:

Appears in 1 contract

Samples: Double Taxation Agreement

BUSINESS PROFITS. 1. The profits from business profits of activities derived by an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise of a Contracting State carries on business as aforesaidin the other Contracting State through a permanent establishment situated therein, the profits of the enterprise may be taxed in the other State Contracting Stat but only so much of them as is directly or indirectly attributable to that permanent establishment.

Appears in 1 contract

Samples: auditors.am

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State State, through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, aforesaid the profits of the enterprise may be taxed in the other State but only so much of them as is directly or indirectly attributable to that permanent establishment.

Appears in 1 contract

Samples: www.incometaxindia.gov.in

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other Contracting State but only so much of them as is directly or indirectly attributable to to: (a) that permanent establishment.;

Appears in 1 contract

Samples: Agreement

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other State but only on so much of them thereof as is directly or indirectly attributable to that permanent establishment.. Income Tax Act section 106

Appears in 1 contract

Samples: www.frcs.org.fj

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries or has carried on business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is directly or indirectly attributable to that permanent establishment.

Appears in 1 contract

Samples: www.gtakorea.org

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. 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 directly or indirectly attributable to that permanent establishment.to:

Appears in 1 contract

Samples: Agreement

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable only in that State unless the enterprise carries on in business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, aforesaid the profits of the enterprise may be taxed in the other State but only so much of them as is directly or indirectly attributable to that permanent establishment.

Appears in 1 contract

Samples: Double Taxation Agreement

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on the business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is directly or indirectly are attributable to that permanent establishment.

Appears in 1 contract

Samples: Double Taxation Avoidance Agreement

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than one of the profits from the operation of ships in international traffic, two States shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. 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 directly or indirectly attributable to that permanent establishment or are derived within such other State from sales of goods or merchandise of the same kind as those sold, or from other business transaction of the same kind as those effected, through the permanent establishment.

Appears in 1 contract

Samples: Agreement

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable taxation only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. 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 directly or indirectly attributable to that permanent establishment.to:

Appears in 1 contract

Samples: Agreement

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. 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 directly attributable to: that (a)permanent establishment; sales in that other State of goods or indirectly attributable to merchandise of the same or similar (b) kind as those sold through that permanent establishment.; or other business activities carried on in that other State of the

Appears in 1 contract

Samples: datacenter.ortax.org

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on or has carried on business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is directly or indirectly attributable to that permanent establishment.attributable:

Appears in 1 contract

Samples: South African Revenue

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BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than one of the profits from the operation of ships in international traffic, two States shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. 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 directly or indirectly attributable to that permanent establishment or are derived within such other State from sales of goods or merchandise of the same kind as those sold, or from other business transactions of the same kind as those effected, through the permanent establishment.

Appears in 1 contract

Samples: datacenter.ortax.org

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable only in that Contracting State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. therein If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other Contracting State but only so much of them as is directly or indirectly attributable to that permanent establishment.

Appears in 1 contract

Samples: Agreement

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. 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 directly or indirectly attributable to (a) that permanent establishment or, (b) sales in that other State of goods or merchandise of the same or similar kind as those sold through that permanent establishment.

Appears in 1 contract

Samples: www.incometaxindia.gov.in

BUSINESS PROFITS. 1. The business profits of an enterprise of a one of the Contracting State, other than the profits from the operation of ships in international traffic, States shall be taxable only in that Contracting State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other Contracting State but only so much of them as is directly or indirectly attributable to that permanent establishment.

Appears in 1 contract

Samples: www.incometaxindia.gov.in

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State Stale through a permanent establishment situated therein. 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 directly or indirectly attributable to that permanent establishment.,

Appears in 1 contract

Samples: Agreement

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other State State, but only so much of them as is directly or indirectly attributable to that permanent establishment.

Appears in 1 contract

Samples: Taxation Agreement

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable only in that Contracting State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the an enterprise may be taxed in the other Contracting State but only so much of them as is directly or indirectly attributable to that permanent establishment.to:

Appears in 1 contract

Samples: Double Taxation Avoidance Agreement

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable only in that State unless Contracting State. However, if the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other State Contracting States but only so much of them as is directly or indirectly attributable to that permanent establishment. This is without prejudice to the right of taxation of such profits by the first-mentioned Contracting State according to its tax laws.

Appears in 1 contract

Samples: www.incometaxindia.gov.in

BUSINESS PROFITS. 1. The business profits Profits of an enterprise of a Contracting State, other than the profits from the operation of ships in international traffic, State shall be taxable only in that Contracting State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits profits that are attributable to the permanent establishment in accordance with the provisions of the enterprise paragraph 2 may be taxed in the that other State but only so much of them as is directly or indirectly attributable to that permanent establishmentContracting State.

Appears in 1 contract

Samples: www2.deloitte.com

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