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General Conditions For The Supply Of Plant And Machinery For Export Foreign Collaboration & Joint Venture 1299

Category: Foreign Collaboration And Joint Venture

paragraph A of the Appendix of that part of the price payable under the Contract which is properly attributable to such portion of the Plant as cannot in consequence of the said failure be put to the use … or, if no sum be named, that part of the price payable under the Contract which is properly attributable to such portion of the Plant as could not in consequence of the Vendor’s failure be put to the


France

Category: Agreements Double Taxation Agreements With Different Countries

the enterprise may be taxed in the other Contracting State but only so much of them as is attributable to that permanent establishment.2. Subject to the provisions of paragraph 3, where an enterprise of one of the Contracting … the enterprise of which it is a permanent establishment. In any case where the correct amount of profits attributable to a permanent establishment is incapable of determination or the determination thereof presents exceptional difficulties, the profits attributable to


United States Of America

Category: Agreements Double Taxation Agreements With Different Countries

of the enterprise may be taxed in the other State but only so much of them as is attributable to (a) that permanent establishment; (b) sales in the other State of goods or merchandise of the same or … subject to the same common control as that enterprise. In any case where the correct amount of profits attributable to a permanent establishment is incapable of determination or the determination thereof presents exceptional difficulties, the profits attributable to


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Canada

Category: Agreements Double Taxation Agreements With Different Countries

the enterprise of which it is a permanent establishment. In any case, where the correct amount of profits attributable to a permanent establishment is incapable of determination or the ascertainment thereof presents exceptional difficulties, the profits attributable to … of the enterprise may be taxed in the other State but only so much of them as is attributable to:a. that permanent establishment; andb. sales of goods and merchandise of the same or similar kind as those sold,


Denmark

Category: Agreements Double Taxation Agreements With Different Countries

of the enterprise may be taxed in the other State but only so much of them as is attributable to (a) that permanent establishment; (b) sales in that other State of goods or merchandise of the same or … the enterprise of which it is a permanent establishment. In any case where the correct amount of profits attributable to a permanent establishment is incapable of determination or the determination thereof presents exceptional difficulties, the profits attributable to


Singapore

Category: Agreements Double Taxation Agreements With Different Countries

may be taxed in the other State but only so much of them as is directly or indirectly attributable to, that permanent establishment.2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries … the enterprise of which it is a permanent establishment. In any case where the correct amount of profits attributable to a permanent establishment is incapable of determination or the determination thereof presents exceptional difficulties, the profits attributable to


Syria

Category: Agreements Double Taxation Agreements With Different Countries

the enterprise may be taxed in the other Contracting State but only so much of them as is attributable to that permanent establishment. This is without prejudice to the right of taxation of such profits by the first-mentioned … wholly independently with the enterprise of which it is a permanent establishment. Where the correct amount of profits attributable to a permanent establishment cannot be determined or the determination thereof presents exceptional difficulties, the profits attributable to the


Tanzania

Category: Agreements Double Taxation Agreements With Different Countries

the enterprise may be taxed in the other Contracting State but only so much of them as is attributable to that permanent establishment.2. If an enterprise of a Contracting State, which has a permanent establishment in the other … may be attributed to the permanent establishment unless the enterprise proves that such sales or services are not attributable to the activity of the permanent establishment.3. Where an enterprise, of a Contracting State carries on business in the


Zambia

Category: Agreements Double Taxation Agreements With Different Countries

the enterprise may be taxed in the other Contracting State but only so much of them as is attributable to that permanent establishment.2. If an enterprise of a Contracting State, which has a permanent establishment in the other … may be attributed to the permanent establishment unless the enterprise proves that such sales or services are not attributable to the activity of the permanent establishment.3. Where an enterprise of a Contracting State carries on business in the


Poland

Category: Agreements Double Taxation Agreements With Different Countries

of the enterprise may be taxed in the other State but only so much of them as is attributable to (a) that permanent establishment; (b) sales in that other State of goods or merchandise of the same or … the enterprise of which it is a permanent establishment. In any case where the correct amount of profits attributable to a permanent establishment is incapable of determination or the determination thereof presents exceptional difficulties, the profits attributable to


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