State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. United States Congressional Serial Set - Page 51987Full view - About this book
| Hans Jörg Geiser, Pamela Alleyne, Carroll Gajraj - 1976 - 298 pages
...various parts, nothing in paragraph 3 of this Article shall preclude that State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment shall however be such that the result shall be in accordance with the principles laid down in this... | |
| Helmut Loukota, Albert J. Rädler, Josef Schuch, Franz Wassermeyer, Gerald Toifl, Christoph Urtz - 1998 - 266 pages
...its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may...accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that... | |
| Pasquale Pistone - 2002 - 424 pages
...to its various parts, nothing in para. 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may...accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that... | |
| United Nations Staff - 2002 - 564 pages
...its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may...accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that... | |
| Radhakishan Rawal - 2006 - 551 pages
...nothing in paragraph (2) of this Article shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may...apportionment adopted shall, however, be such that the result is in accordance with the principles embodied in this Article. " 8.5.2 Can an administrative practice... | |
| 416 pages
...its various parts, nothing in paragraph (2) shall prelude that Contracting State from determining the profits to be taxed by such an apportionment as may...with the principles contained in this Article. (6) Where a permanent establishment takes an active and substantial part in the negotiation and conclusion... | |
| 2005 - 524 pages
...its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may...accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that... | |
| 460 pages
...enterprise to its various parts, nothing in paragraph 2 shall preclude that State from determining the profits to be taxed by such an apportionment as may...accordance with the principles contained in this article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that... | |
| 468 pages
...its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may...accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that... | |
| 486 pages
...enterprise to its various parts, nothing in paragraph 2 shall preclude that State from determining the profits to be taxed by such an apportionment as may...accordance with the principles contained in this article. 5 . No profits shall be attributed to a permanent establishment by reason of the mere purchase of goods... | |
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