 | 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... | |
 | 1980 - 476 pages
...latter, In their commercial or financial relations, conditions different from those which would be male with an independent enterprise, any profits which...States derives from the operation of ships or aircraft shall be exempt from taxation In the other contracting State. (2) The provisions of this Article shall... | |
 | 1968 - 416 pages
...the other contracting State, makes with or Imposes on the latter, in their commercial or financia! relations, conditions different from those which would...profits of that enterprise and taxed accordingly. ABTICLK V (1) Income which an enterprise of one of the contracting States derives from the operation... | |
 | 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,... | |
 | Great Britain - 1961 - 1446 pages
...would be made between independent enterprises, any profits, which would, out 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, profits derived by a resident of the United... | |
 | United States. Internal Revenue Service - 1955 - 1158 pages
...State, agrees to, or imposes on the latter enterprise, commercial or financial conditions differing from those which would be made with an independent...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,... | |
 | Great Britain. Foreign Office, Great Britain. Foreign and Commonwealth Office - 1958 - 1048 pages
...States may lay down rules by agreement for the apportionment of industrial and commercial profits. Where an enterprise of one of the contracting States,...of that enterprise and taxed accordingly. ARTICLE 5 (1) Income which an enterprise of one of the contracting States derives from the operation of ships... | |
 | 1960 - 510 pages
...financial structure of an enterprise of the other contracting State, makes with or imposes on the latter, m their commercial or financial relations, conditions...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... | |
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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... 
