 | United States. Congress. Senate. Committee on Finance - 1946 - 910 pages
...Contracting Parties is engaged in trade or business in the territory of the other Contracting Party through a permanent establishment situated therein, there...shall, subject to the law of such other Contracting Party, be deemed to be income from sources within the territory of such other Contracting Party. (4)... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1945 - 138 pages
...establishment in New York, under paragraph (3) of article III there shall be attributed to the New York branch the industrial or commercial profits which it might...profits so attributed shall, subject to the law of the country in question, be deemed to be income from sources within its territory. However, in accordance... | |
 | United States. Congress. Senate. Foreign Relations - 1945 - 94 pages
...establishment in New York, under paragraph (3) of article III there shall be attributed to the New York branch the industrial or commercial profits which it might...profits so attributed shall, subject to the law of the country in question, be deemed to be income from sources within its territory. However, in accordance... | |
 | United States. Congress. Joint Committee on Internal Revenue Taxation - 1946 - 428 pages
...Contracting Parties is engaged in trade or business in the territory of the other Contracting Party through a permanent establishment situated therein, there...shall, subject to the law of such other Contracting Party, be deemed to be income from .sources within the territory of such other Contracting Party. (4)... | |
 | 1974 - 436 pages
...were an independent enterprise engaged In the same or similar activities under the same or sunliar conditions and dealing at arm's length with the enterprise...shall, subject to the law of such other Contracting Party, be deemed to be Income from sources within the territory of auch other Contracting Party. (4)... | |
 | United States - 1954 - 830 pages
...contracting States of the mere purchase of merchandise therein by an enterprise of the other State. (3) Where an enterprise of one of the contracting...at arm's length with the enterprise of which it is a permanent establishment. (4) In the determination of the industrial or commercial profits of the... | |
 | United States. Internal Revenue Service - 1967 - 1388 pages
...Contracting Parties is engaged in trade or business In the territory of the other Contracting Party through a permanent establishment situated therein, there...at arm's length with the enterprise of which it is a permanent establishment. (3) In determining the industrial or commercial profits of an enterprise... | |
 | Great Britain - 1961 - 1446 pages
...industrial or commercial profits which it might be expected to derive in that other territory if k were an independent enterprise engaged in the same...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,... | |
 | United States Congress. Economic Joint Committee - 1959 - 548 pages
...(Decree-Law of the Provisional Head of the State). dustrial or commercial profits such establishment might be expected to derive if it were an independent...similar conditions and dealing at arm's length with the United States corporation. The Convention also provides that the taxes imposed in both countries on... | |
 | 1960 - 510 pages
...the permanent establishment, Including executive and general administrative expenses so allocable. (3) Where an enterprise of one of the contracting...other contracting State, be deemed to be Income from source« within the territory of such other contracting State. (4) The competent authorities of the... | |
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States is engaged In trade or business in the territory of the other contracting State through a permanent establishment situated therein, there shall be attributed to such permanent establishment the industrial or commercial profits which it might be... 
