Permanent establishment profit attribution limited to remuneration for actual activities, not total contract value under the tax treaty protocol. Profit attribution for permanent establishments under Article 7 is limited to remuneration attributable to the actual activities undertaken by the permanent establishment in the host Contracting State, rather than the enterprise's total receipts. In contracts for survey, supply, installation, construction or public works, the taxable profit of the permanent establishment is measured only by the part of the contract effectively carried out by that permanent establishment in the host State.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Permanent establishment profit attribution limited to remuneration for actual activities, not total contract value under the tax treaty protocol.
Profit attribution for permanent establishments under Article 7 is limited to remuneration attributable to the actual activities undertaken by the permanent establishment in the host Contracting State, rather than the enterprise's total receipts. In contracts for survey, supply, installation, construction or public works, the taxable profit of the permanent establishment is measured only by the part of the contract effectively carried out by that permanent establishment in the host State.
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