 | United States. Congress. Senate. Committee on Foreign Relations - 1982 - 532 lapas
...actual expenses) '..;• 1 >. permanent establishment to any office of the resident by way of royi .s, fees, or other similar payments in return for the use of patents or other rights; commissions for specific services performed or for management; and, except for banking institutions,... | |
 | 1987 - 948 lapas
...commission for specific services performed or for management, or by way of interest on moneys lent to the head office of the enterprise or any of its other offices. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed... | |
 | 1997 - 68 lapas
...the enterprise, other than reimbursements of actual expenses. Such amounts include royalties, fees or similar payments in return for the use of patents or other rights; commissions or other charges for specific services performed or for management; or interest on moneys... | |
 | United Nations Staff - 2002 - 564 lapas
...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. 4. Subject to the provisions of paragraph 3, insofar as it has been customary in a Contracting State... | |
 | 2004 - 80 lapas
...office, of the enterprise that includes the permanent establishment if such payments constitute: (1) royalties, fees or other similar payments in return for the use of patents, know-how or other rights; (2) commissions or other charges for specific services performed or for management;... | |
 | Radhakishan Rawal - 2006 - 551 lapas
...banking activities? Para 3 provides that "no deduction shall be allowed in respect of amounts paid by the Permanent Establishment to the head office of the enterprise or to any of its other offices ... except in case of a banking enterprise, by way of interest on moneys... | |
 | 416 lapas
...However, no such deduction shall be allowed in respect of amounts, if any, paid (otherwise than by way of reimbursement of actual expenses) by the permanent...in return for the use of patents or other rights, or by way of a commission, for specific services performed or for management, or, except in the case... | |
 | 420 lapas
...However, no such deduction shall be allowed in respect of amounts, if any, paid (otherwise than towards reimbursement of actual expenses) by the permanent...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... | |
 | United Nations - 524 lapas
...any. paid (otherwise than towards reimbursement of actual expenses) by the permanent establishment to the enterprise or any of its other offices, by way...similar payments in return for the use of patents or ocher rights, or by way of commission, for specific services performed or for management, or. except... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1977 - 522 lapas
...than reimbursement of actual expenses) by the permanent establishment to any office of the resident by way of royalties, fees, or other similar payments in return for the use of patents or other rights ; commissions for specific services performed or for management ; and. except for banking institutions,... | |
| |
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,... 
