Common use of With respect to Clause in Contracts

With respect to. Article 7 a) In the case of contracts for constructions or installations or any survey related to construction or installation, the profits of a permanent establishment shall not be determined on the total amount of the contract, but shall be determined only on the basis of that part of the contract, which is effectively carried out by the permanent establishment in the state where the permanent establishment is situated and any portion of the contract executed outside the other Contracting State shall not be taken into consideration in determining the profits of the permanent establishment. b) It is understood that, business profits derived by an enterprise of a Contracting State from the exportation of merchandise to the other Contracting State shall not be taxed in that other Contracting State. Where export contracts include other activities carried on through a permanent establishment in the other Contracting State, profits attributable to such activities may be taxed in the other Contracting State. c) It is understood that, the term “business profits” includes, but is not limited to income derived from manufacturing, mercantile, banking, insurance, from the operation of inland transportation, the furnishing of services. Such a term does not include the performance of personal services by an individual either as an employee or in an independent capacity.

With respect to. Article 7 a) a. In the case of contracts for constructions or installations or any survey related to construction or installation, the profits of a permanent establishment shall not be determined on the total amount of the contract, but shall be determined only on the basis of that part of the contract, which is effectively carried out by the permanent establishment in the state where the permanent establishment is situated and any portion of the contract executed outside the other Contracting State shall not be taken into consideration in determining the profits of the permanent establishment. b) b. It is understood that, business profits derived by an enterprise of a Contracting State from the exportation of merchandise to the other Contracting State shall not be taxed in that other Contracting State. Where export contracts include other activities carried on through a permanent establishment in the other Contracting State, profits attributable to such activities may be taxed in the other Contracting State. c) c. It is understood that, the term “"business profits” " includes, but is not limited to income derived from manufacturing, mercantile, banking, insurance, from the operation of inland transportation, the furnishing of services. Such a term does not include the performance of personal services by an individual either as an employee or in an independent capacity.