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" ... separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. "
Joint Venture Agreements in Romania: Background for Implementation - Page 51
by Pompiliu Verzariu, Jay A. Burgess - 1977 - 98 pages
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Internal Revenue Bulletin: Cumulative bulletin, Issue 2

United States. Internal Revenue Service - 1968 - 1034 pages
...length with the resident of which it 1* a permanent establishment. (3) In the determination of the profits of a permanent establishment, there shall...deductions expenses which are reasonably connected with snch profits including executive and general administrative expenses, whether incurred in the State...
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Statutory Instruments, Part 3

Great Britain - 1961 - 1446 pages
...dealing at arm's length with the enterprise of which it is a permanent establishment. (4) In determining the industrial or commercial profits of a permanent...establishment, there shall be allowed as deductions all expenses which would be deductible if the permanent establishment were an independent enterprise...
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Investment in India: Basic Information for United States Businessmen

United States. Bureau of Foreign Commerce. Far Eastern Division, Celia I. Herman - 1961 - 286 pages
...the profits attributable to the establishment may be estimated on a reasonable basis. In determining the industrial or commercial profits of a permanent...establishment there shall be allowed as deductions all expenses, wherever incurred, reasonably allocable to such permanent establishment, including executive...
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Legislative History of United States Tax Conventions

United States. Congress. Joint Committee on Internal Revenue Taxation - 1962 - 1532 pages
...similar activities under the same or similar conditions and dealing at arm's length with the enterprise of which it is a permanent establishment. (3) In the...determination of the industrial or commercial profits of the permanent establishment there shall be allowed as deductions all expenses which are reasonably...
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Legislative History of United States Tax Conventions

United States. Congress. Joint Committee on Internal Revenue Taxation - 1962 - 1528 pages
...similar activities under the same or similar conditions and dealing at arm's length with the enterprise of which it is a permanent establishment. (3) In the...determination of the industrial or commercial profits of the permanent establishment there shall be allowed as deductions all expenses which are reasonably...
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Legislative History of United States Tax Conventions

United States. Congress. Joint Committee on Internal Revenue Taxation - 1962 - 1516 pages
...the profits attributable to the establishment may be estimated on a reasonable basis. In determining the industrial or commercial profits of a permanent...establishment there shall be allowed as deductions all expenses, wherever incurred, reasonably allocable to such permanent establishment, including executive...
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Model tax conventions

United States. Congress. Joint Committee on Internal Revenue Taxation - 1962 - 724 pages
...activities under the same or similar conditions and dealing quite independently with the enterprise of which it is a permanent establishment. 3. In the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred...
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Tax Convention with Thailand: Hearings, Eighty-ninth Congress, First Session ...

United States. Congress. Senate. Committee on Foreign Relations - 1965 - 196 pages
...commercial profits of that resident or corporation from sources within tbat other Contracting State. (3) In the determination of the industrial or commercial profits of a resident or corporation of one of the Contracting States having a permanent establishment in the other...
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Internal Revenue Cumulative Bulletin

United States. Internal Revenue Service - 1976 - 624 pages
...the same or similar activities under the same or similar conditions and dealing wholly independently with the resident of which it is a permanent establishment....permanent establishment, there shall be allowed as deduction expenses which are reasonably connected with such profits, including executive and general...
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Internal Revenue Cumulative Bulletin

United States. Internal Revenue Service - 1977
...activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. (3) In the determination of the profits of a permanent establishment there shall be allowed as deductions expenses which are incurred...
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