Protocol

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....ntegral part of the Convention : 1. To Article 7 (Business Profits) : (a) In respect of paragraph 1, the profits attributable to a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall include profits directly or indirectly attributable to the permanent establishment and in particular shall include profits of the enterprise from the sales in ....

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....the determination of the profits of a permanent establishment, for amounts charged (otherwise than towards reimbursement of actual expenses), by the permanent establishment to the head office of the enterprise or any other of its offices, by way of royalties, fees or other similar payments in return for the use of patents, know-how or other rights, or by way of commission or other charges, for spe....