 | United States. Congress. Senate. Foreign Relations - 1945 - 94 pages
...which would be made with an independent enterprise, any profits which would but for those conditions have accrued to one of the enterprises, but by reason...profits of that enterprise and taxed accordingly. Hence, the Treasury now has recognition of its powers under section 45 to assure the proper allocation... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1945 - 138 pages
...which would be made with an independent enterprise, any profits which would but for those conditions have accrued to one of the enterprises,, but by reason...profits of that enterprise and taxed accordingly. Hence, the Treasury now ha» recognition of its powers under section 45 to assure the proper allocation... | |
 | United States. Congress. Joint Committee on Internal Revenue Taxation - 1946 - 428 pages
...which would be made with an independent enterprise, any profits which would but for those conditions have accrued to one of the enterprises but by reason...that enterprise and taxed accordingly. Article V (1) Notwithstanding the provisions of Articles III and IV of the present Convention, profits which an individual... | |
 | 1990 - 216 pages
...case of Denmark, the Chief of the Taxation Department of the Ministry of Finance (Generaldirektoren for Skattevaesenet) or his authorized representative....from the operation of ships or aircraft registered hi that State shall be exempt from taxation in the other contracting State. (2) The present Convention... | |
 | 1999 - 240 pages
...States may lay down rules by agreement for the apportionment of industrial and commercial profits. ARTICLE IV Where an enterprise of one of the contracting...of that enterprise and taxed accordingly. ARTICLE V Income which an enterprise of one of the contracting States derives from the operation of ships or... | |
 | 1998 - 212 pages
...States may lay down rules by agreement for the apportionment of industrial and commercial profits. ARTICLE IV Where an enterprise of one of the contracting...of that enterprise and taxed accordingly. ARTICLE v Income which an enterprise of one of the contracting States derives from the operation of ships or... | |
 | 1999 - 220 pages
...lay down rules by agreement for the apportionment of industrial and commercial profits. ARTICLE rv Where an enterprise of one of the contracting States,...of that enterprise and taxed accordingly. ARTICLE V Income which an enterprise of one of the contracting States derives from the operation of ships or... | |
 | 1974 - 436 pages
...may lay down rules by agreement for the apportionment of industrial and commercial profits. ARTXCLS IV Where an enterprise of one of the contracting States,...profits of that enterprise and taxed accordingly. ARITCLE V (1) Income which an enterprise of one of the contracting States derives from the operation... | |
 | 1954 - 1486 pages
...which would be made with an independent enterprise, any profits which would but for those conditions have accrued to one of the enterprises but by reason...profits of that enterprise and taxed accordingly. £ETICLS v (1) NotwIthstanding the provisions of Articles III and IV of the present Convention, profits... | |
 | United States - 1954 - 830 pages
...the latter enterprise, commercial or financial conditions differing from those which would be nade with an Independent enterprise, any profits which...of that enterprise and taxed accordingly. Article V Profits derived by an enterprise of one of the contractIng States from the operation of ships or aircraft,... | |
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State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions... 
