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Germany – Jamaica · Source editionArticle 7 Business Profits

Unreviewed · applicability unverified
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(1)

(1) The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on trade or business in the other Contracting State through a permanent establishment situated there- in, If the enterprise carries on trade or business as afore- said, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment.

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(2)

(2) Where an enterprise of a Contracting State carries on trade or business in the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing at arm’s length with the enterprise of which it is a perma- nent establishment.

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(3)

(3) In determining the profits of a permanent establish- ment situated in one of the Contracting States, there shall be allowed as deductions all expenses which would be deductible under the law of that Contracting State if the permanent establishment were an independent enter- prise in so far as such expenses are reasonably allocable to the permanent establishment including executive and general administration expenses so deductible and allocable, whether incurred in that Contracting State in which the permanent establishment is situated or else- where.

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(4)

(4) Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a per- manent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph (2) shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles laid down in this Article.

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(5)

(5) No profits shall be attributed to a permanent estab- lishment by reason of the mere purchase by that perma- nent establishment of goods or merchandise for the enterprise,

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(6)

(6) If the information available to the competent authority concerned is inadequate to determine the profits to be attributed to the permanent establishment, such profits may be determined by the exercise of a dis- cretion or the making of an estimate by that competent authority, provided that such discretion shall be exercis- ed or such estimate shall be made in accordance with the principles stated in this Article.

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(7)

(7) For the purposes of the preceding paragraph the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.

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(8)

(8) Where profits include items of income which are dealt with separately in other Articles of this Agree- ment, then the provisions of those Articles shall not be affected by the provisions of this Article.

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Source, edition and limits
Source edition
de-jamaica-1976-base | BGBl. 1976 II S. 1194 | signed 1974-10-08 | published 1976-07-17 | Signed: 1974-10-08 | Gazette publication: 1976-07-17
Source form
unchanged official-publication scan; separate 260-dpi local OCR machine transcription, NOT original native text
Source scope
original consent-law publication and base treaty with accompanying protocol; not current consolidated law
Retrieved
2026-09-30
Text and language scope
The original closing specifies German and English, equally authentic. No third authentic language is identified by these retained originals/audit; this is not a full-language accuracy certification. All text is unreviewed OCR, including retained wrong glyphs, punctuation, hyphens and spacing. Treaty preamble, closing, protocol, signatures, implementing law and any notes are retained separately at /review/de-jamaica-1976-base/. Exact physical-page spans and unresolved OCR at /review/de-jamaica-1976-base/evidence/. Source-page links are page references, not verified paragraph alignment.
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 as current law. Signed 1974-10-08; consent law 1976-07-14; gazette publication 1976-07-17. Edition ID year is not a signature date. Treaty entry into force: 1976-09-13. Roster general application: 1973-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 13. September 1976. Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. 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
Printed signature protocol retained separately and not merged into articles. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated 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
Citation
BGBl. 1976 II S. 1194
SHA-256
9c21e0ddbeda70f9067191a616ffc242edf0320f0cdfe618b53669f0f64c982c

Citation

Copyable citation

BGBl. 1976 II S. 1194 | de-jamaica-1976-base | de-jamaica-1976-base | BGBl. 1976 II S. 1194 | signed 1974-10-08 | published 1976-07-17 | Signed: 1974-10-08 | Gazette publication: 1976-07-17 | Article 7 | en | Pending human wording, completeness, source authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-jamaica-1976-base/en/articles/article-7/

Disclaimers

Language switching retains matching article and paragraph identifiers. The mapping does not confirm reviewed legal or translational equivalence.

BGBl. 1976 II S. 1194

Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.

Source details · Preamble and protocol

Source-page links are references, not human paragraph verification.

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