business profits means income derived from any trade or business whether carried on by an individual, corporation or any other person, or group of persons, including the rental of tangible personal (movable) property.
business profits. Nothing in this Agreement shall affect the operation of any law of a Contracting State relating to the taxation of income or profits from any insurance business provided that if the relevant law in force in either Contracting State at the date of signature of this Agreement is amended (otherwise than in minor respects so as not to affect its general character) the States shall consult with each other with a view to agreeing to any amendment of this paragraph that may be appropriate.
business profits means income derived from any trade or business including income from the furnishing of services other than included services as defined in Article 12 (Royalties and Fees for Included Services) and including income from the rental of tangible personal property other than property described in paragraph 3(b) of Article 12 (Royalties and Fees for Included Services).
More Definitions of business profits
business profits. Industrial and Commercial Profits" or "Other Income" provisions, if any, of such treaty (i) before the first Scheduled Payment Date with respect to any such Transaction and thereafter during each third succeeding calendar year, (ii) promptly upon reasonable demand by the Guarantor, and (iii) promptly upon learning that any such form previously provided has become obsolete or incorrect.
business profits or "Industrial or Commercial Profits" provision, as the case may be, the "Interest" provision or the "Other Income" provision (if any) of the Specified Treaty with respect to any payment described in such provisions and received or to be received by it in connection with this Agreement and no such payment is attributable to a trade or business carried on by it through a permanent establishment in the Specified Jurisdiction. If such representation applies:
business profits or "Industrial or Commercial Profits" provision, as the case may be, the "Interest" provision or the "Other Income" provision (if any) of the tax treaty between the United Kingdom and Australia with respect to any payment described in such provisions and received or to be received by it in connection with this Agreement and no such payment is attributable to a trade or business carried on by it through a permanent establishment in Australia. Party B makes the following representations: It is an Australian resident and does not derive payments under this Agreement in part or in whole carrying on business in a country outside Australia at or through a permanent establishment or itself in that country. The Trust is a non-U.S. branch of a foreign person for U.S. federal income tax purposes.
business profits or "Industrial or Commercial Profits" provision, as the case may be, the "Interest" provision or the "Other Income" provision (if any) of the tax treaty between the United Kingdom and Australia with respect to any payment described in such provisions and received or to be received by it in connection with this Agreement and no such payment is attributable to a trade or business carried on by it through a permanent establishment in Australia. It is a non-U.S. branch of a foreign person for U.S. federal income tax purposes. Party B makes the following representations: It is an Australian resident and does not derive payments under this Agreement in part or in whole carrying on business in a country outside Australia at or through a permanent establishment or itself in that country. The Trust is a non-U.S. branch of a foreign person for U.S. federal income tax purposes.
business profits means income derived by an enterprise from the carrying on of business; but does not include income in the form of rents, royalties (including rents or royalties in respect of cinematographic films or video tapes for television), fees for technical services, management charges, or remuneration or fees for providing services of technical or other personnel, interest, dividends, capital gains, remuneration for labour or personal (including professional) services or income from the operation of ships or aircraft.
business profits and "business lossess" do not include gains or losses of a capital nature to which Article 8 of this Taxation Code applies. Article 5 Dividends 1. Dividends which are paid by a company which is a resident of a Contracting State wholly or partly out of profits derived from sources in Area A, and which are beneficially owned by a resident of the other Contracting State, may be taxed only in that other Contracting State. 2. The term "dividends" as used in this Article means income from shares or other rights participating in profits and not relating to debt claims, as well as other income which is subjected to the same taxation treatment as income from shares by the law of the Contracting State of which the company making the distribution is a resident. Article 6 Interest 1. Interest paid by a contractor, being interest to which a resident of a Contracting State is beneficially entitled, may be taxed in that Contracting State. 2. Such interest may also be taxed in the other Contracting State, but the tax so charged shall not exceed ten (10) per cent of the gross amount of the interest. 3. Where such interest is taxed in the other Contracting State in accordance with paragraph 2 of this Article, that interest shall, for the purposes of determining a foreign tax credit entitlement under the taxation law of the Contracting State referred to in paragraph 1 of this Article, be deemed to be income derived from sources in the other Contracting State. 4. Interest paid by a contractor, being interest to which a person who is not a resident of either Contracting State is beneficially entitled, may be taxed in both Contracting States but the taxable amount of any such interest shall be an amount equivalent to fifty (50) per cent of the amount that would be the taxable amount but for this paragraph. Article 7 Royalties 1. Royalties paid by a Contractor, being royalties to which a resident of a Contracting State is beneficially entitled, may be taxed in that Contracting State. 2. Such royalties may also be taxed in the other Contracting State, but the tax so charged shall not exceed ten (10) per cent of the gross amount of the royalties. 3. Where such royalties are taxed in the other Contracting State in accordance with paragraph 2 of this Article, those royalties shall, for the purposes of determining a foreign tax credit entitlement under the taxation law of the Contracting State referred to in paragraph 1 of this Article, be deemed to be income derived from sources in ...