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    <description>Profits are taxable in the State of residence unless an enterprise carries on business in the other State through a permanent establishment, in which case only profits attributable to that permanent establishment, related sales, or similar activities may be taxed there. Attribution is determined as if the permanent establishment were a distinct and independent enterprise dealing at arm&#039;s length, allowance is made for expenses incurred for the permanent establishment&#039;s business subject to the taxing State&#039;s laws, and transactions that are not reimbursements between head office and offices do not alter profits attributable to the permanent establishment.</description>
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      <description>Profits are taxable in the State of residence unless an enterprise carries on business in the other State through a permanent establishment, in which case only profits attributable to that permanent establishment, related sales, or similar activities may be taxed there. Attribution is determined as if the permanent establishment were a distinct and independent enterprise dealing at arm&#039;s length, allowance is made for expenses incurred for the permanent establishment&#039;s business subject to the taxing State&#039;s laws, and transactions that are not reimbursements between head office and offices do not alter profits attributable to the permanent establishment.</description>
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