Traduction de «être au bénéfice d'une autorisation d'établissement » (Français → Anglais) :

(b) where a company which is a resident of Canada has a permanent establishment in Brazil, this permanent establishment may be subject to a tax withheld at source in accordance with Brazilian law, but such a tax cannot exceed 15 per cent of the gross amount of the profits of that permanent establishment determined after the payment of the corporate tax related to such profits.

2. With reference to paragraphs 1 and 2 of Article 7 of the Agreement, it is understood that where an enterprise of a Contracting State sells goods or merchandise or otherwise carries on business in the other Contracting State through a permanent establishment situated therein, the profits of that permanent establishment shall be determined only on the basis of the profits that are attributable to the actual activity of the permanent establishment for such business.

Likewise, no account shall be taken, in the determination of the profits of the permanent establishment, for amounts charged (otherwise than towards reimbursement of actual expenses), by the permanent establishment to the head office of the enterprise or any of its other offices, by way of royalties, fees or other similar payments in return for the use of patents or other rights, or by way of commission for services performed or for management, or, except in the case of a banking enterprise, by way of interest on moneys lent to the he ...[+++]ad office of the enterprise or any of its other offices.

Likewise, no account shall be taken, in the determination of the profits of a permanent establishment, for amounts charged (otherwise than towards reimbursement of actual expenses), by the permanent establishment to the head office of the enterprise or any of its other offices, by way of royalties, fees, or other similar payments in return for the use of patents or other rights, or by way of commission for specific services performed or for management, or, except in the case of a banking enterprise by way of interest on moneys lent to the head office of t ...[+++]he enterprise or any of its other offices.

2. Licence holders shall establish and implement management systems which shall be regularly verified by the regulatory body.

To resolve this difficulty, some Member States allow foreign tax to be credited to the domestic tax payable (imputation or tax credit method) while others which exempt the profits of foreign undertakings allow foreign losses to be deducted temporarily in some cases and to be reincorporated at a later date into the results of the head office to the extent of the amounts previously deducted (deduction method with subsequent reincorporation).2 (See annexes) In order to take account of the different practices in Member States but also to rationalize those practices, the proposal for a Directive envisages two technical methods for taking loss ...[+++]es into account that are designed, among other things, to facilitate new transfrontier activities, which, during the start-up phase, often generate losses for undertakings.