Business Profits
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....ofits that are attributable to the permanent establishment in accordance with the provisions of paragraph 2 may be taxed in that other State. 2. For the purposes of this Article and Article [23 A] [23 B], the profits that are attributable in each Contracting State to the permanent establishment referred to in paragraph 1 are the profits it might be expected to make, in particular in its dealing....
TaxTMI