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Business profits

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Full Text of the Document

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....e enterprise may be taxed in the other Contracting States but only so much of them as is attributable to that permanent establishment. This is without prejudice to the right of taxation of such profits by the first-mentioned ContractingState according to its tax laws. 2. Where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establishme....

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Full Text of the Document

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....the business of the permanent establishment including executive and general administrative expenses so incurred, whether in the State 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. For the purposes of the ....