 | United States. Internal Revenue Service - 1977
...enterprise of which it is a permanent establishment, of goods or merchandise for the enterprise. (5) Where / ( R Rd äӲE q GZ ʡ,# { 6F , S : ($[B .=; 0 this Convention, the provisions of those articles shall, except as otherwise provided therein, supersede... | |
 | United States. Internal Revenue Service - 1976 - 624 lapas
...income were accounted for through such permanent establishment. (7) Where industrial or commercial profits include items of income which are dealt with separately in other articles of this Convention, the provisions of those articles shall, except as otherwise provided therein, supersede... | |
 | United States. Internal Revenue Service - 1979 - 644 lapas
...income were accounted for through such permanent establishment. (7) Where industrial or commercial profits include items of income which are dealt with separately in other articles of this Convention, the provisions of those articles shall, except as otherwise provided therein, supersede... | |
 | Hans Jörg Geiser, Pamela Alleyne, Carroll Gajraj - 1976 - 298 lapas
...services or remuneration for personal (including professional) services. 9. Where industrial or commercial profits include items of income which are dealt with separately in other Articles of this Agreement, the provisions of those Articles shall, except as otherwise provided therein, supersede... | |
 | Pompiliu Verzariu, Jay A. Burgess - 1977 - 110 lapas
...income were accounted for through such permanent establishment. (8) Where industrial or commercial profits include items of income which are dealt with separately in other articles of this convention, the provisions of those articles shall, except as otherwise provided therein, supersede... | |
 | United States. Congress. Joint Committee on Taxation - 1979 - 1376 lapas
...respect to its other activities will not be increased by a profit element on its purchasing activities. Where business profits include items of income which...articles of the treaty, those other articles, and not this business profits article, will govern the treatment of those items of income. .4 rticle 8. Shipping... | |
 | United States. Congress. Joint Committee on Taxation - 1979 - 26 lapas
...on its purchasing activities. Where business profits include items of income which are dealt witli separately in other articles of the treaty, those other articles, and not this business profits article, will govern the treatment of those items of income. Article 8. Shipping... | |
 | 1981 - 40 lapas
...respect to its other activities will not be increased by a profits element on its purchasing activities. Where business profits include items of income which...will govern the treatment of those items of income. Unlike the US model treaty, the proposed treaty provides that film royalties are not business profits.... | |
 | United States. Congress. Joint Committee on Taxation - 1981 - 38 lapas
...be treated as business profits subject to Argentine tax. (See Article 5 (Permanent Establishment).) Where business profits include items of income which...articles of the treaty, those other articles, and not this business profits article, will govern the treatment of those items of income. Thus, for example,... | |
 | United States. Congress. Joint Committee on Taxation - 1981 - 34 lapas
...respect to its other activities will not be increased by a profit element on its purchasing activities. Where business profits include items of income which...articles of the treaty, those other articles, and not this business profits article, will govern the treatment of those items of income. Thus, for example,... | |
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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. 
