Page 438 - ΔΟΚΙΜΗ

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ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡΙΛΙΟΥ
1984
429
Ι!
such resitlent i8 50 engaged, tax may be iml)Osed by that
other Contracting State
οη
the industrial or oommercial
profits
ο!
euch resident but only
οη
50
much
ο!
8uoh profits
βθ
are attributable to the permanent establishment.
(2) Where a resident
ο!
a Contracting State
i5
engaged
in industrial or commercial activity
ίη
the other Contracting
State through a permanent establishment situated therein,
there shal1
ίη
eaoh Contracting state be attributed to the
permanent establishment the induetrial or commercial profits
which wou1d be attributable to such permanent establ1shment
if such permanent establishment were an independent entity
engaged
ίη
the eame
οτ
similar activities under the same or
similar conditions.
(3)
Ιη
the determ1nation
ο!
the industrial or commeroial
profits
ο!
a permanent eetablishment, there 8hall be al10wed
βθ
deductions expenses which
βΤθ
reasonably connected with
such profits, including executive and general administrative
expenses, whether lncurred
ίη
the Contracting State
ίη
which
the permanent e5tablishment
ίθ
situated
οτ
elsewhere.
(4)
Νο
profits shall be attributed to a permanent
establishment of a resident
ο!
a Contracting State
ίη
the
other Contracting state merely by reason
ο!
the purchase
ot
goods or merohandise by that permanent establishment, or
by the resident
ο!
which it is a permanent estab1ishment,
for the account
ο!
that resident.
(5)
The term "industrial or commeroial activity" includes
the conduct
ο!
manufacturing, mercantile, banking, insurance,
agricultura1, fishing or mining activ1ties, the operation
ο!
shipe
οτ
aircraft, the furnishing
ο! θθrνίoθθ
and the
rental
ο!
tangible personal property. Such term does not
inc1ude the performance
ο!
personal
eerνices
by
βΩ
individual either
βe βΩ
employee
οτ ίη βΩ
independent
capacity.
(6)
(a) The term "industrial or commercial profits" means
income derived from industrial
οτ
commercia1 activity.
The term 81so includes income derived from rea1
property and natura1 resources and dividende, interest,
royalties (as defined
ίη
paragraph (2) of Artic1e 14
(Royalties», and gains but only if the property or
rlghts giving rise to such income, dividends, interest,
roya1ties,
οτ
gain5
ίβ
effectively connected with a