 | 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 - Double taxation - 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 - Income tax - 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... | |
 | Administrative law - 1990 - 216 pages
...present Convention by one of the contracting States any term not otherwise defined, shall, unless the context otherwise requires, have the meaning which...from the operation of ships or aircraft registered hi that State shall be exempt from taxation in the other contracting State. (2) The present Convention... | |
 | Administrative law - 1980 - 476 pages
...States may lay down rules by agreement for the apportionment of Industrial and commercial profits. ARTICLE IV Where an Enterprise of one of the contracting...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... | |
 | Administrative law - 1998 - 212 pages
...States may lay down rules by agreement for the apportionment of industrial and commercial profits. ARTICLE IV Where an enterprise of one of the contracting...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... | |
 | Administrative law - 1999 - 240 pages
...States may lay down rules by agreement for the apportionment of industrial and commercial profits. ARTICLE IV Where an enterprise of one of the contracting...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... | |
 | Administrative law - 1999 - 220 pages
...lay down rules by agreement for the apportionment of industrial and commercial profits. ARTICLE rv Where an enterprise of one of the contracting States,...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... | |
 | Administrative law - 1974 - 436 pages
...may lay down rules by agreement for the apportionment of industrial and commercial profits. ARTXCLS IV Where an enterprise of one of the contracting States,...profits of that enterprise and taxed accordingly. ARITCLE V (1) Income which an enterprise of one of the contracting States derives from the operation... | |
 | Administrative law - 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... | |
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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... 
