Business profits

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....be taxed in the other State but only so much of them as is attributable to that permanent establishment.] 2. Subject to the provisions of paragraph (3), where an enterprise of one of the Contracting States carries on business in the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the pr....

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....ate in which the permanent establishment is situated or elsewhere. 4. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 5. Where the correct amount of profits attributable to a permanent establishment is incapable of determination by the taxation authority of one of the Contractin....

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....e provisions of this Article. 8. Nothing in this Article shall affect the operation of any law of a Contracting State relating to tax imposed on profits from insurance with non-residents provided that if the relevant law in force in either Contracting State at the date of signature of this Agreement is varied (otherwise than in minor respects so as not to affect its general character) the Contrac....

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.... resident through a permanent establishment situated therein and that share of business profits shall be attributed to that permanent establishment. *************** NOTES:- 1. Substituted vide Notification No. 74/2013 dated September 20, 2013, w.e.f. The provisions of the Protocol annexed hereto shall be given effect to and shall be deemed to have been given effect to in the Union of India in ....