{"component": "clause", "props": {"groups": [{"snippet": "1. The profits of an enterprise of a Contracting 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 afore- said, 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.\n2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment situated therein, there shall in each Contracting State be attributed to that perma- nent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.\n3. In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establish- ment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere.\n4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article.\n5. 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.\n6. 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.\n7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.", "samples": [{"hash": "dFP6gz8srax", "uri": "/contracts/dFP6gz8srax#business-profits", "label": "Convention for the Avoidance of Double Taxation", "score": 34.7950210571, "published": true}, {"hash": "fPCNzqEStV5", "uri": "/contracts/fPCNzqEStV5#business-profits", "label": "Convention for the Avoidance of Double Taxation", "score": 33.722869873, "published": true}, {"hash": "61udSnW3sys", "uri": "/contracts/61udSnW3sys#business-profits", "label": "Convention for the Avoidance of Double Taxation", "score": 33.6851387024, "published": true}], "size": 378, "snippet_links": [{"key": "contracting-state", "type": "definition", "offset": [37, 54]}, {"key": "the-enterprise", "type": "clause", "offset": [98, 112]}, {"key": "other-contracting", "type": "definition", "offset": [140, 157]}, {"key": "other-state", "type": "definition", "offset": [320, 331]}, {"key": "subject-to-the-provisions", "type": "clause", "offset": [412, 437]}, {"key": "paragraph-3", "type": "clause", "offset": [441, 452]}, {"key": "engaged-in", "type": "definition", "offset": [781, 791]}, {"key": "activities-under", "type": "clause", "offset": [812, 828]}, {"key": "profits-of-a-permanent-establishment", "type": "clause", "offset": [979, 1015]}, {"key": "purposes-of-the", "type": "clause", "offset": [1090, 1105]}, {"key": "administrative-expenses", "type": "definition", "offset": [1165, 1188]}, {"key": "in-the-state", "type": "definition", "offset": [1210, 1222]}, {"key": "determine-the", "type": "clause", "offset": [1348, 1361]}, {"key": "basis-of", "type": "clause", "offset": [1423, 1431]}, {"key": "apportionment-of", "type": "clause", "offset": [1435, 1451]}, {"key": "total-profits", "type": "definition", "offset": [1456, 1469]}, {"key": "paragraph-2", "type": "definition", "offset": [1521, 1532]}, {"key": "method-of", "type": "clause", "offset": [1662, 1671]}, {"key": "in-accordance-with", "type": "clause", "offset": [1743, 1761]}, {"key": "the-principles", "type": "clause", "offset": [1762, 1776]}, {"key": "contained-in", "type": "definition", "offset": [1777, 1789]}, {"key": "establishment-of", "type": "clause", "offset": [1916, 1932]}, {"key": "goods-or-merchandise", "type": "definition", "offset": [1933, 1953]}, {"key": "sufficient-reason", "type": "definition", "offset": [2160, 2177]}, {"key": "other-articles", "type": "clause", "offset": [2271, 2285]}, {"key": "affected-by", "type": "definition", "offset": [2357, 2368]}, {"key": "provisions-of-this-article", "type": "clause", "offset": [2373, 2399]}], "hash": "5006eeba2b2dde5e0b20f1b4a94b8741", "id": 3}, {"snippet": "1. The profits of an enterprise of a Contracting 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 attributable to that permanent establishment.\n2. Subject to the provisions of paragraph 3, 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 that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.\n3. In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere.\n4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article.\n5. 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.\n6. 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.\n7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.", "samples": [{"hash": "hYeF0Qlmp4B", "uri": "/contracts/hYeF0Qlmp4B#business-profits", "label": "Convention for the Avoidance of Double Taxation", "score": 21.9864673615, "published": true}, {"hash": "d3Cp9f9AAe7", "uri": "/contracts/d3Cp9f9AAe7#business-profits", "label": "Convention for the Avoidance of Double Taxation", "score": 21.9864673615, "published": true}, {"hash": "d2x4xADNwoz", "uri": "/contracts/d2x4xADNwoz#business-profits", "label": "Convention for the Avoidance of Double Taxation", "score": 21.9864673615, "published": true}], "size": 355, "snippet_links": [{"key": "contracting-state", "type": "definition", "offset": [37, 54]}, {"key": "the-enterprise", "type": "clause", "offset": [98, 112]}, {"key": "other-contracting", "type": "definition", "offset": [140, 157]}, {"key": "other-state", "type": "definition", "offset": [336, 347]}, {"key": "subject-to-the-provisions", "type": "clause", "offset": [428, 453]}, {"key": "paragraph-3", "type": "clause", "offset": [457, 468]}, {"key": "engaged-in", "type": "definition", "offset": [793, 803]}, {"key": "activities-under", "type": "clause", "offset": [824, 840]}, {"key": "profits-of-a-permanent-establishment", "type": "clause", "offset": [989, 1025]}, {"key": "purposes-of-the", "type": "clause", "offset": [1100, 1115]}, {"key": "administrative-expenses", "type": "definition", "offset": [1173, 1196]}, {"key": "in-the-state", "type": "definition", "offset": [1218, 1230]}, {"key": "determine-the", "type": "clause", "offset": [1356, 1369]}, {"key": "basis-of", "type": "clause", "offset": [1431, 1439]}, {"key": "apportionment-of", "type": "clause", "offset": [1443, 1459]}, {"key": "total-profits", "type": "definition", "offset": [1464, 1477]}, {"key": "paragraph-2", "type": "definition", "offset": [1529, 1540]}, {"key": "method-of", "type": "clause", "offset": [1670, 1679]}, {"key": "in-accordance-with", "type": "clause", "offset": [1751, 1769]}, {"key": "the-principles", "type": "clause", "offset": [1770, 1784]}, {"key": "contained-in", "type": "definition", "offset": [1785, 1797]}, {"key": "establishment-of", "type": "clause", "offset": [1924, 1940]}, {"key": "goods-or-merchandise", "type": "definition", "offset": [1941, 1961]}, {"key": "sufficient-reason", "type": "definition", "offset": [2168, 2185]}, {"key": "other-articles", "type": "clause", "offset": [2279, 2293]}, {"key": "affected-by", "type": "definition", "offset": [2365, 2376]}, {"key": "provisions-of-this-article", "type": "clause", "offset": [2381, 2407]}], "hash": "67d4c140046fece0c4fa9cc2705d5194", "id": 4}, {"snippet": "1. The profits of an enterprise of a Contracting 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 attributable to that permanent establishment.\n2. Subject to the provisions of paragraph 3, 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 that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.\n3. In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere.\n4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article.\n5. 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.\n6. 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.\n7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.", "samples": [{"hash": "LxbhkLBbNp", "uri": "/contracts/LxbhkLBbNp#business-profits", "label": "Convention for the Avoidance of Double Taxation", "score": 35.1640052795, "published": true}, {"hash": "5HKCPNbhhFt", "uri": "/contracts/5HKCPNbhhFt#business-profits", "label": "Convention for the Avoidance of Double Taxation", "score": 34.0791435242, "published": true}, {"hash": "iQxJG6pbzbT", "uri": "/contracts/iQxJG6pbzbT#business-profits", "label": "Convention for the Elimination of Double Taxation", "score": 33.8847885132, "published": true}], "size": 685, "snippet_links": [{"key": "contracting-state", "type": "definition", "offset": [37, 54]}, {"key": "the-enterprise", "type": "clause", "offset": [98, 112]}, {"key": "other-contracting", "type": "definition", "offset": [140, 157]}, {"key": "other-state", "type": "definition", "offset": [318, 329]}, {"key": "subject-to-the-provisions", "type": "clause", "offset": [410, 435]}, {"key": "paragraph-3", "type": "clause", "offset": [439, 450]}, {"key": "engaged-in", "type": "definition", "offset": [775, 785]}, {"key": "activities-under", "type": "clause", "offset": [806, 822]}, {"key": "profits-of-a-permanent-establishment", "type": "clause", "offset": [971, 1007]}, {"key": "purposes-of-the", "type": "clause", "offset": [1082, 1097]}, {"key": "administrative-expenses", "type": "definition", "offset": [1155, 1178]}, {"key": "in-the-state", "type": "definition", "offset": [1200, 1212]}, {"key": "determine-the", "type": "clause", "offset": [1338, 1351]}, {"key": "basis-of", "type": "clause", "offset": [1413, 1421]}, {"key": "apportionment-of", "type": "clause", "offset": [1425, 1441]}, {"key": "total-profits", "type": "definition", "offset": [1446, 1459]}, {"key": "paragraph-2", "type": "definition", "offset": [1511, 1522]}, {"key": "method-of", "type": "clause", "offset": [1652, 1661]}, {"key": "in-accordance-with", "type": "clause", "offset": [1733, 1751]}, {"key": "the-principles", "type": "clause", "offset": [1752, 1766]}, {"key": "contained-in", "type": "definition", "offset": [1767, 1779]}, {"key": "establishment-of", "type": "clause", "offset": [1906, 1922]}, {"key": "goods-or-merchandise", "type": "definition", "offset": [1923, 1943]}, {"key": "sufficient-reason", "type": "definition", "offset": [2150, 2167]}, {"key": "other-articles", "type": "clause", "offset": [2261, 2275]}, {"key": "affected-by", "type": "definition", "offset": [2347, 2358]}, {"key": "provisions-of-this-article", "type": "clause", "offset": [2363, 2389]}], "hash": "13c82793550e07ba8c05c4fb3f685c06", "id": 1}, {"snippet": "(1) The profits of an enterprise of a Contracting 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 attributable to that permanent establishment.\n(2) Subject to the provisions of paragraph 3, 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 that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.\n(3) In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 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 its other offices, by way of royalties, fees or other similar payments in return 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 establishment. Likewise, no account shall be taken, in the determination of the profits of a permanent establishment, for amounts charged (otherwise than towards reimbursement of actual 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 return 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 head office of the enterprise or any of its other offices.\n(4) Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article.\n(5) 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.\n(6) Where profits include items of income which are dealt with separately in other Articles of this Agreement, then the provisions of those Articles shall not be affected by the provisions of this Article.", "samples": [{"hash": "ia9hinPFChA", "uri": "/contracts/ia9hinPFChA#business-profits", "label": "Agreement for the Avoidance of Double Taxation", "score": 24.483915329, "published": true}, {"hash": "hBtakdX0mp2", "uri": "/contracts/hBtakdX0mp2#business-profits", "label": "Double Taxation Agreement", "score": 19.0, "published": true}, {"hash": "gpoyOKbh6MI", "uri": "/contracts/gpoyOKbh6MI#business-profits", "label": "Double Taxation Agreement", "score": 19.0, "published": true}], "size": 389, "snippet_links": [{"key": "contracting-state", "type": "definition", "offset": [38, 55]}, {"key": "the-enterprise", "type": "clause", "offset": [99, 113]}, {"key": "other-contracting", "type": "definition", "offset": [141, 158]}, {"key": "other-state", "type": "definition", "offset": [319, 330]}, {"key": "subject-to-the-provisions", "type": "clause", "offset": [412, 437]}, {"key": "paragraph-3", "type": "clause", "offset": [441, 452]}, {"key": "engaged-in", "type": "definition", "offset": [777, 787]}, {"key": "activities-under", "type": "clause", "offset": [808, 824]}, {"key": "profits-of-a-permanent-establishment", "type": "clause", "offset": [974, 1010]}, {"key": "purposes-of-the", "type": "clause", "offset": [1085, 1100]}, {"key": "administrative-expenses", "type": "definition", "offset": [1158, 1181]}, {"key": "in-the-state", "type": "definition", "offset": [1203, 1215]}, {"key": "in-respect-of", "type": "definition", "offset": [1323, 1336]}, {"key": "actual-expenses", "type": "definition", "offset": [1400, 1415]}, {"key": "office-of-the", "type": "clause", "offset": [1460, 1473]}, {"key": "other-offices", "type": "clause", "offset": [1499, 1512]}, {"key": "in-return", "type": "clause", "offset": [1566, 1575]}, {"key": "use-of-patents", "type": "clause", "offset": [1584, 1598]}, {"key": "other-rights", "type": "clause", "offset": [1602, 1614]}, {"key": "services-performed", "type": "clause", "offset": [1654, 1672]}, {"key": "for-management", "type": "clause", "offset": [1676, 1690]}, {"key": "in-the-case", "type": "clause", "offset": [1703, 1714]}, {"key": "interest-on", "type": "clause", "offset": [1750, 1761]}, {"key": "determination-of-the", "type": "clause", "offset": [1850, 1870]}, {"key": "determine-the", "type": "clause", "offset": [2472, 2485]}, {"key": "basis-of", "type": "clause", "offset": [2547, 2555]}, {"key": "apportionment-of", "type": "clause", "offset": [2559, 2575]}, {"key": "total-profits", "type": "definition", "offset": [2580, 2593]}, {"key": "paragraph-2", "type": "definition", "offset": [2645, 2656]}, {"key": "method-of", "type": "clause", "offset": [2786, 2795]}, {"key": "in-accordance-with", "type": "clause", "offset": [2867, 2885]}, {"key": "the-principles", "type": "clause", "offset": [2886, 2900]}, {"key": "contained-in", "type": "definition", "offset": [2901, 2913]}, {"key": "sufficient-reason", "type": "definition", "offset": [3115, 3132]}, {"key": "other-articles", "type": "clause", "offset": [3227, 3241]}, {"key": "this-agreement", "type": "clause", "offset": [3245, 3259]}, {"key": "affected-by", "type": "definition", "offset": [3312, 3323]}, {"key": "provisions-of-this-article", "type": "clause", "offset": [3328, 3354]}], "hash": "bcfd82f33c208e204acdaeb6509b8062", "id": 2}, {"snippet": "1. The profits of an enterprise of a Contracting 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 enterprise may be taxed in that other Contracting State but only so much of them as is attributable to that permanent establishment.\n2. Subject to the provisions of paragraph 3, 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 that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.\n3. In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establishment, including executive and general administrative expenses so incurred, whether in the Contracting State in which the permanent establishment is situated or elsewhere.\n4. 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.\n5. For the purposes of the preceding paragraphs of this Article, 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.\n6. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.", "samples": [{"hash": "5RrEZuBbyqe", "uri": "/contracts/5RrEZuBbyqe#business-profits", "label": "Convention for the Elimination of Double Taxation", "score": 33.7130050659, "published": true}, {"hash": "3wSTzFHoj6L", "uri": "/contracts/3wSTzFHoj6L#business-profits", "label": "Convention for the Elimination of Double Taxation", "score": 32.0151672363, "published": true}, {"hash": "gEok92cu8Eh", "uri": "/contracts/gEok92cu8Eh#business-profits", "label": "Convention for the Elimination of Double Taxation", "score": 31.7879657745, "published": true}], "size": 255, "snippet_links": [{"key": "contracting-state", "type": "definition", "offset": [37, 54]}, {"key": "the-enterprise", "type": "clause", "offset": [110, 124]}, {"key": "other-contracting", "type": "definition", "offset": [152, 169]}, {"key": "subject-to-the-provisions", "type": "clause", "offset": [435, 460]}, {"key": "paragraph-3", "type": "clause", "offset": [464, 475]}, {"key": "engaged-in", "type": "definition", "offset": [800, 810]}, {"key": "activities-under", "type": "clause", "offset": [831, 847]}, {"key": "profits-of-a-permanent-establishment", "type": "clause", "offset": [996, 1032]}, {"key": "purposes-of-the", "type": "clause", "offset": [1107, 1122]}, {"key": "administrative-expenses", "type": "definition", "offset": [1180, 1203]}, {"key": "the-contracting", "type": "clause", "offset": [1228, 1243]}, {"key": "establishment-of", "type": "clause", "offset": [1425, 1441]}, {"key": "goods-or-merchandise", "type": "definition", "offset": [1442, 1462]}, {"key": "sufficient-reason", "type": "definition", "offset": [1685, 1702]}, {"key": "other-articles", "type": "clause", "offset": [1796, 1810]}, {"key": "affected-by", "type": "definition", "offset": [1882, 1893]}, {"key": "provisions-of-this-article", "type": "clause", "offset": [1898, 1924]}], "hash": "dc912e87ad28f7567a111351ae1360ca", "id": 5}, {"snippet": "1. The profits of an enterprise of a Contracting 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 attributable to that permanent establishment.\n2. Subject to the provisions of paragraph 3, 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 that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.\n3. In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere.\n4. 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.\n5. 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.\n6. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.", "samples": [{"hash": "gGWXksD0W6E", "uri": "/contracts/gGWXksD0W6E#business-profits", "label": "Convention for the Avoidance of Double Taxation", "score": 34.2625465393, "published": true}, {"hash": "83j2j2fv9yG", "uri": "/contracts/83j2j2fv9yG#business-profits", "label": "Convention for the Avoidance of Double Taxation", "score": 33.8163566589, "published": true}, {"hash": "koSUCJpJr5y", "uri": "/contracts/koSUCJpJr5y#business-profits", "label": "Convention for the Avoidance of Double Taxation", "score": 33.7314949036, "published": true}], "size": 200, "snippet_links": [{"key": "contracting-state", "type": "definition", "offset": [37, 54]}, {"key": "the-enterprise", "type": "clause", "offset": [98, 112]}, {"key": "other-contracting", "type": "definition", "offset": [140, 157]}, {"key": "other-state", "type": "definition", "offset": [318, 329]}, {"key": "subject-to-the-provisions", "type": "clause", "offset": [410, 435]}, {"key": "paragraph-3", "type": "clause", "offset": [439, 450]}, {"key": "engaged-in", "type": "definition", "offset": [775, 785]}, {"key": "activities-under", "type": "clause", "offset": [806, 822]}, {"key": "profits-of-a-permanent-establishment", "type": "clause", "offset": [971, 1007]}, {"key": "purposes-of-the", "type": "clause", "offset": [1082, 1097]}, {"key": "administrative-expenses", "type": "definition", "offset": [1155, 1178]}, {"key": "in-the-state", "type": "definition", "offset": [1200, 1212]}, {"key": "establishment-of", "type": "clause", "offset": [1388, 1404]}, {"key": "goods-or-merchandise", "type": "definition", "offset": [1405, 1425]}, {"key": "sufficient-reason", "type": "definition", "offset": [1632, 1649]}, {"key": "other-articles", "type": "clause", "offset": [1743, 1757]}, {"key": "affected-by", "type": "definition", "offset": [1829, 1840]}, {"key": "provisions-of-this-article", "type": "clause", "offset": [1845, 1871]}], "hash": "8f734a6c80afcbdfda463034cc64043f", "id": 6}, {"snippet": "1. The profits of an enterprise of a Contracting 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 attributable to that permanent establishment.\n2. Subject to the provisions of paragraph 3, 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 that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently.\n3. In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere.\n4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article.\n5. 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.\n6. 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.\n7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.", "samples": [{"hash": "hxW0xEGhtww", "uri": "/contracts/hxW0xEGhtww#business-profits", "label": "Convention for the Avoidance of Double Taxation", "score": 33.1268463135, "published": true}, {"hash": "6g5BbkzVhZB", "uri": "/contracts/6g5BbkzVhZB#business-profits", "label": "Convention for the Avoidance of Double Taxation", "score": 24.6386032104, "published": true}, {"hash": "idcGVsNTEv6", "uri": "/contracts/idcGVsNTEv6#business-profits", "label": "Convention for the Avoidance of Double Taxation", "score": 21.2737846375, "published": true}], "size": 173, "snippet_links": [{"key": "contracting-state", "type": "definition", "offset": [37, 54]}, {"key": "the-enterprise", "type": "clause", "offset": [98, 112]}, {"key": "other-contracting", "type": "definition", "offset": [140, 157]}, {"key": "other-state", "type": "definition", "offset": [318, 329]}, {"key": "subject-to-the-provisions", "type": "clause", "offset": [410, 435]}, {"key": "paragraph-3", "type": "clause", "offset": [439, 450]}, {"key": "engaged-in", "type": "definition", "offset": [775, 785]}, {"key": "activities-under", "type": "clause", "offset": [806, 822]}, {"key": "profits-of-a-permanent-establishment", "type": "clause", "offset": [910, 946]}, {"key": "purposes-of-the", "type": "clause", "offset": [1021, 1036]}, {"key": "administrative-expenses", "type": "definition", "offset": [1094, 1117]}, {"key": "in-the-state", "type": "definition", "offset": [1139, 1151]}, {"key": "determine-the", "type": "clause", "offset": [1277, 1290]}, {"key": "basis-of", "type": "clause", "offset": [1352, 1360]}, {"key": "apportionment-of", "type": "clause", "offset": [1364, 1380]}, {"key": "total-profits", "type": "definition", "offset": [1385, 1398]}, {"key": "paragraph-2", "type": "definition", "offset": [1450, 1461]}, {"key": "method-of", "type": "clause", "offset": [1591, 1600]}, {"key": "in-accordance-with", "type": "clause", "offset": [1672, 1690]}, {"key": "the-principles", "type": "clause", "offset": [1691, 1705]}, {"key": "contained-in", "type": "definition", "offset": [1706, 1718]}, {"key": "establishment-of", "type": "clause", "offset": [1845, 1861]}, {"key": "goods-or-merchandise", "type": "definition", "offset": [1862, 1882]}, {"key": "sufficient-reason", "type": "definition", "offset": [2089, 2106]}, {"key": "other-articles", "type": "clause", "offset": [2200, 2214]}, {"key": "affected-by", "type": "definition", "offset": [2286, 2297]}, {"key": "provisions-of-this-article", "type": "clause", "offset": [2302, 2328]}], "hash": "2a278354da2ca0c8dc54fe88a1259ecb", "id": 7}, {"snippet": "The profits of an enterprise of a Contracting 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 attributable to that permanent establishment.", "samples": [{"hash": "9DFf0zZ1iD", "uri": "/contracts/9DFf0zZ1iD#business-profits", "label": "Convention for the Avoidance of Double Taxation", "score": 33.5782051086, "published": true}, {"hash": "fzIKRIT1uxV", "uri": "/contracts/fzIKRIT1uxV#business-profits", "label": "Convention for the Avoidance of Double Taxation", "score": 33.5316696167, "published": true}, {"hash": "dMusnprhfI7", "uri": "/contracts/dMusnprhfI7#business-profits", "label": "Convention for the Avoidance of Double Taxation", "score": 33.5316696167, "published": true}], "size": 171, "snippet_links": [{"key": "contracting-state", "type": "definition", "offset": [34, 51]}, {"key": "the-enterprise", "type": "clause", "offset": [95, 109]}, {"key": "other-contracting", "type": "definition", "offset": [137, 154]}, {"key": "permanent-establishment", "type": "clause", "offset": [171, 194]}, {"key": "other-state", "type": "definition", "offset": [315, 326]}], "hash": "5e0715ad1fcc764838dec572d6a79c63", "id": 8}, {"snippet": "1. The profits of an enterprise of a Contracting 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 attributable to that permanent establishment.\n2. Subject to the provisions of paragraph 3, 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 that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.\n3. In determining the profits of a permanent establishment, there shall be allowed as deductions all expenses, including executive and general administrative expenses, which would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the Contracting State in which the permanent establishment is situated or elsewhere.\n4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article.\n5. 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.\n6. 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.\n7. Where profits include items of income which are dealt with separately in other Articles of this Agreement, then the provisions of those Articles shall not be affected by the provisions of this Article.", "samples": [{"hash": "kZcBqYIpCPR", "uri": "/contracts/kZcBqYIpCPR#business-profits", "label": "Double Taxation Agreement", "score": 33.7581977844, "published": true}, {"hash": "fRJRclqPWi7", "uri": "/contracts/fRJRclqPWi7#business-profits", "label": "Double Taxation Agreement", "score": 33.0882148743, "published": true}, {"hash": "cZCx2aqnqXl", "uri": "/contracts/cZCx2aqnqXl#business-profits", "label": "Agreement for the Elimination of Double Taxation", "score": 32.9513473511, "published": true}], "size": 161, "snippet_links": [{"key": "contracting-state", "type": "definition", "offset": [37, 54]}, {"key": "the-enterprise", "type": "clause", "offset": [98, 112]}, {"key": "other-contracting", "type": "definition", "offset": [140, 157]}, {"key": "other-state", "type": "definition", "offset": [318, 329]}, {"key": "subject-to-the-provisions", "type": "clause", "offset": [410, 435]}, {"key": "paragraph-3", "type": "clause", "offset": [439, 450]}, {"key": "engaged-in", "type": "definition", "offset": [775, 785]}, {"key": "activities-under", "type": "clause", "offset": [806, 822]}, {"key": "profits-of-a-permanent-establishment", "type": "clause", "offset": [971, 1007]}, {"key": "administrative-expenses", "type": "definition", "offset": [1092, 1115]}, {"key": "independent-enterprise", "type": "definition", "offset": [1182, 1204]}, {"key": "the-contracting", "type": "clause", "offset": [1299, 1314]}, {"key": "determine-the", "type": "clause", "offset": [1446, 1459]}, {"key": "basis-of", "type": "clause", "offset": [1521, 1529]}, {"key": "apportionment-of", "type": "clause", "offset": [1533, 1549]}, {"key": "total-profits", "type": "definition", "offset": [1554, 1567]}, {"key": "paragraph-2", "type": "definition", "offset": [1619, 1630]}, {"key": "method-of", "type": "clause", "offset": [1760, 1769]}, {"key": "in-accordance-with", "type": "clause", "offset": [1841, 1859]}, {"key": "the-principles", "type": "clause", "offset": [1860, 1874]}, {"key": "contained-in", "type": "definition", "offset": [1875, 1887]}, {"key": "establishment-of", "type": "clause", "offset": [2014, 2030]}, {"key": "goods-or-merchandise", "type": "definition", "offset": [2031, 2051]}, {"key": "purposes-of-the", "type": "clause", "offset": [2083, 2098]}, {"key": "sufficient-reason", "type": "definition", "offset": [2258, 2275]}, {"key": "other-articles", "type": "clause", "offset": [2369, 2383]}, {"key": "this-agreement", "type": "clause", "offset": [2387, 2401]}, {"key": "affected-by", "type": "definition", "offset": [2454, 2465]}, {"key": "provisions-of-this-article", "type": "clause", "offset": [2470, 2496]}], "hash": "f98fb4ab12dca5e4e308e26eaea8e84c", "id": 9}, {"snippet": "1. The profits of an enterprise of a Contracting 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 attributable to that permanent establishment.\n2. Subject to the provisions of paragraph 3, 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 that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.\n3. In the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere, which are allowed under the provisions of the domestic law of the Contracting State in which the permanent establishment is situated.\n4. In so far as it has been customary in a contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article.\n5. 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.\n6. 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.\n7. 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specify calculation methods to ensure consistency; allocate tax responsibilities clearly to prevent disputes.", "explanation": "The BUSINESS PROFITS clause defines how profits generated from business activities are to be calculated, allocated, and distributed among relevant parties. Typically, this clause outlines the method for determining net profits, specifies any allowable deductions or expenses, and may set forth the timing and manner of profit distribution. Its core practical function is to ensure transparency and fairness in the sharing of business earnings, thereby preventing disputes over financial entitlements and clarifying each party\u2019s share of the profits."}, "json": true, "cursor": ""}}