Common use of With reference to Article Clause in Contracts

With reference to Article. 7 a) In the Contracting State in which the permanent establishment is situated, no profits shall be attributed to a building site, a construction, assembly or installation project except those which are the result of such activities themselves. Profits derived from the supply of goods connected with, or independent of, such activities and effected by the principal permanent establishment or any other permanent establishment of the enterprise or by a third party shall not be attributed to the building site, a construction, assembly or installation project. b) Income derived from design, planning, engineering or research or from technical services which a resident of a Contracting State performs in that Contracting State and which are connected with a permanent establishment referred to in sub-paragraph a) in the other Contracting State shall not be attributed to that permanent establishment.

With reference to Article. 7 (a) In the Contracting State in which the permanent establishment is situated, no profits shall be attributed to a building site, a construction, assembly site or construction or installation project except those which are the result of such activities themselves. Profits derived from the supply of goods or merchandise connected with, or independent of, such activities and effected delivered by the principal permanent establishment or any other permanent establishment of the enterprise or by a third party person shall not be attributed to the building site, a construction, assembly site or construction or installation project. (b) Income derived from planning, design, planning, engineering or research or from technical services which a resident of a Contracting State performs in that Contracting State and which are connected with a permanent establishment referred to in sub-paragraph a) in the other Contracting State shall not be attributed to that permanent establishment.