1. Profits of an enterprise of a Contracting State shall be tax-
able only in that State unless the enterprise carries on business
in the other Contracting State through a permanent establish-
ment situated therein. If the enterprise carries on business as
aforesaid, the profits that are attributable to the permanent es-
tablishment in accordance with the provisions of paragraph 2
may be taxed in that other State.
2. For the purposes of this Article and Article 22, the profits
that are attributable in each Contracting State to the permanent
establishment referred to in paragraph 1 are the profits it might
be expected to make, in particular in its dealings with other parts
of the enterprise, if it were a separate and independent enterprise
engaged in the same or similar activities under the same or
similar conditions, taking into account the functions performed,
assets used and risks assumed by the enterprise through the
permanent establishment and through the other parts of the
enterprise.
3. Where, in accordance with paragraph 2, a Contracting
State adjusts the profits that are attributable to a permanent es-
tablishment of an enterprise of one of the Contracting States and
taxes accordingly profits of the enterprise that have been
charged to tax in the other State, the other Contracting State
shall, to the extent necessary to eliminate double taxation, make
an appropriate adjustment if it agrees with the adjustment made
by the first-mentioned State; if the other Contracting State does
not so agree, the Contracting States shall endeavour to eliminate
any double taxation resulting therefrom by mutual agreement.
4. Where profits include items of income which are dealt with
separately in other Articles of this Agreement, then the provisions
of those Articles shall not be affected by the provisions of this
Article.
de-armenia-2017-base | BGBl. 2017 II S. 1077 | Signed: 2016-06-29 | Gazette publication: 2017-07-27
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
This source supplies German and English versions. The signing clause also identifies Armenian as authentic; that third version is NOT present in this reader. Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-armenia-2017-base/. PDF page links identify pages, not verified paragraph correspondence.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown. No current-law consolidation, effective-period determination, MLI application, or complete amendment-chain verification has been performed. Original publication year is not a current applicability date. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Protocols and later instruments
The protocol printed with this agreement is separately preserved in source supplements; it has not been merged into treaty articles. Subsequent protocols, amendments, MLI effects, replacements and suspensions are unresolved. This is not a consolidated current-law instrument. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Text language and status
en · authentic-language-transcription · machine-transcription
BGBl. 2017 II S. 1077 | de-armenia-2017-base | de-armenia-2017-base | BGBl. 2017 II S. 1077 | Signed: 2016-06-29 | Gazette publication: 2017-07-27 | Article 7 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-armenia-2017-base/en/articles/article-7/
Source, edition and limits
Source edition
de-armenia-2017-base | BGBl. 2017 II S. 1077 | Signed: 2016-06-29 | Gazette publication: 2017-07-27
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
This source supplies German and English versions. The signing clause also identifies Armenian as authentic; that third version is NOT present in this reader. Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-armenia-2017-base/. PDF page links identify pages, not verified paragraph correspondence.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown. No current-law consolidation, effective-period determination, MLI application, or complete amendment-chain verification has been performed. Original publication year is not a current applicability date. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Protocols and later instruments
The protocol printed with this agreement is separately preserved in source supplements; it has not been merged into treaty articles. Subsequent protocols, amendments, MLI effects, replacements and suspensions are unresolved. This is not a consolidated current-law instrument. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Text language and status
en · authentic-language-transcription · machine-transcription