With reference to Article 7. For the purposes of paragraph 3, it is understood that the term “expenses which are incurred for the purposes of the permanent establishment” means expenses which would be deductible if the permanent establishment were an independent enterprise of the Contracting State in which the permanent establishment is situated, and which are reasonably allocable to the permanent establishment.
Appears in 3 contracts
Sources: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement, Double Taxation Agreement