租税条約 第7条（事業利潤）
令和7年10月31日|p.24
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ARTICLE7
BUSINESS PROFITS
1. Profits of an enterprise of a Contracting State shall be taxable only in that
Contracting State unless the enterprise carries on business in the other Contracting State
through a permanent establishment situated therein. If the enterprise carries on business
as aforesaid, the profits that are attributable to the permanent establishment in accordance
with the provisions of paragraph 2 may be taxed in that other Contracting 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 establishment 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 Contracting State, that other Contracting State shall, to the extent necessary to
eliminate double taxation on these profits, make an appropriate adjustment to the amount
of the tax charged therein on those profits. In determining such adjustment, the
competent authorities of the Contracting States shall if necessary consult each other.
4. Where profits include items of income which are dealt with separately in other
Articles of this Convention, then the provisions of those Articles shall not be affected by
the provisions of this Article.