 | United States. Internal Revenue Service - 1976 - 624 pages
...income were accounted for through such permanent establishment. (7) Where industrial or commercial profits include items of income which are dealt with separately in other articles of this Convention, the provisions of those articles shall, except as otherwise provided therein, supersede... | |
 | United States. Internal Revenue Service - 1977
...enterprise of which it is a permanent establishment, of goods or merchandise for the enterprise. (5) Where / ( R Rd äӲE q GZ ʡ,# { 6F , S : ($[B .=; 0 this Convention, the provisions of those articles shall, except as otherwise provided therein, supersede... | |
 | United States. Internal Revenue Service - 1979 - 644 pages
...income were accounted for through such permanent establishment. (7) Where industrial or commercial profits include items of income which are dealt with separately in other articles of this Convention, the provisions of those articles shall, except as otherwise provided therein, supersede... | |
 | Hans Jörg Geiser, Pamela Alleyne, Carroll Gajraj - 1976 - 298 pages
...services or remuneration for personal (including professional) services. 9. Where industrial or commercial profits include items of income which are dealt with separately in other Articles of this Agreement, the provisions of those Articles shall, except as otherwise provided therein, supersede... | |
 | Pompiliu Verzariu, Jay A. Burgess - 1977 - 110 pages
...income were accounted for through such permanent establishment. (8) Where industrial or commercial profits include items of income which are dealt with separately in other articles of this convention, the provisions of those articles shall, except as otherwise provided therein, supersede... | |
 | United States. Congress. Joint Committee on Taxation - 1979 - 1376 pages
...respect to its other activities will not be increased by a profit element on its purchasing activities. Where business profits include items of income which...dealt with separately in other articles of the treaty, those other articles, and not this business profits article, will govern the treatment of those items... | |
 | United States. Congress. Joint Committee on Taxation - 1981 - 34 pages
...respect to its other activities will not be increased by a profit element on its purchasing activities. Where business profits include items of income which...dealt with separately in other articles of the treaty, those other articles, and not this business profits article, will govern the treatment of those items... | |
 | 1981 - 40 pages
...respect to its other activities will not be increased by a profits element on its purchasing activities. Where business profits include items of income which...dealt with separately in other articles of the treaty, those other articles, and not the business profits article, will govern the treatment of those items... | |
 | 1987 - 948 pages
...determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where business profits include items of income which are dealt with separately in other Articles of this Agreement, then, the provisions of those Articles shall not be affected by the provisons of this... | |
 | United States. Congress. Joint Committee on Taxation - 1990 - 70 pages
...determined by the same method each year unless there is good and sufficient reason to change the method. Where business profits include items of income which...are dealt with separately in other articles of the proposed treaty, those other articles, and not the Business Profits Article, will govern the treatment... | |
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For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 
