Page 437 - ΔΟΚΙΜΗ

428 ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡΙΛΙΟΥ 1984
οτ paragraph 4 of Article 14 (Royalties) apply, lnterest,
royalties and other disbursements paid by a resident ο'! a
Contracting state to a resident of the other Contracting
State ehall, for the purpose of determining the taxable
profits of the first-mentioned resident, be deductible
under the same conditions θθ ί'! they had been pald to a
reeldent ο! the first-mentioned Contracting State. For
pur:poses ο'! this paragraph, the term "other disbursemente"
ehall include charges for amounts expended by a reeident
ot a Contracting State 'for purposes ο'! a resident ο'! the
other Contracting State, including a r~asonable allocation
ο! executive and general administrative expen8es (except
to the extent representing the expenses of a type ο'!
activity which 18 not for the benefit of the resident ο!
the other Contracting Ste.te, but consti tute "stetφvardshil'''
or "over-seeing" functions undertaken for the first mentioned
resident's οννη benefit as ΒΩ investor), researoh and
development, and other eXI)enses incurred by suoh resident
for the benefit ο! a group ο! related persons including
such resident. Similarly, any debts ο! a resident of a
Contracting state to a resident ο! the other Contractlng
State shall, for the purpose ο! determining the taxable
capital ο! such first-mentioned resident, be deductible
under the same conditions ΒΒ ί! they had been contracted to
a resident ο! the first-mentioned Contraoting State.
(4) Α corporation ο! a Contracting state, the capital
of which is wholly or partly owned οτ controlled, directly
or indirectly, by οηθ οτ more residents ο! the other
Contracting State shall not be subjected ίη the first–
mentioned Contracting State to any taxation or any
requirement connected therewith which i8 other or more
burdensome than the taxation and connected requirements to
which other sirnilar corporations ο! the first-mentioned
Contractiηg State βΤθ or may be subjected.
Article 8
BUSINESS PROFITS
(1) Industrial οτ commercial profits of a resident of a
Contracting state shall be exernpt from tax by the other
Contr~cting State unless euch resident is engaged ίη
industrial οτ commercial activity ίη that other Contraoting
state through a permanent establishrnent situated therein.