Permanent establishment tax

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.... the company subject to tax in the United States which represents the dividend equivalent amount; and (ii ) the excess, if any, of interest deductible in the United States in computing the profits of the company that are subject to tax in the United States and either attributable to a permanent establishment in the United States or subject to tax in the United States under Article 6 [Inco....

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.... (c) The tax referred to in sub-paragraph (a) shall not be imposed at a rate exceeding: (i) the rate specified in paragraph 2(a) of Article 10 (Dividends) for the tax described in sub-paragraph (a)(i); and (ii) the rate specified in paragraph 2(a) or (b) (whichever is appropriate) or Article 11 (Interest) for the tax described in sub-paragraph (a)(ii). 2. A company which is ....