S.L. 123.172 Art. 3there shall be of the business administrative is in respect of expenses) by of its other for the use of performed or of interest on be taken, in charged the permanent by way or other management, lent to the

In determining the profits of a permanent establishment, allowed as deductions expenses which are incurred for the purposes of the permanent establishment, including executive and general expenses so incurred, whether in the State in which the permanent establishment situated or elsewhere. However, no such deduction shall be allowed amounts, if any, paid (otherwise than towards reimbursement of actual the permanent establishment to the head office of the enterprise or any offices, by way of royalties, fees or other similar payments in return patents or other rights, or by way of commission, for specific services for management, or, except in the case of a banking enterprise, by way moneys lent to the permanent establishment. Likewise, no account shall the determination of the profits of a permanent establishment, for amounts (otherwise than towards reimbursement of actual expenses), by establishment to the head office of the enterprise or any of its other offices, of royalties, fees or other similar payments in return for the use of patents rights, or by way of commission for specific services performed or for or, except in the case of banking enterprise by way of interest on moneys head office of the enterprise or any of its other offices.