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ARTICLE 7

U.S. Income Tax Treaty — Jamaica Income Tax Treaty - 1980 · 2026-10-03 edition · updated 2026-10-04 · United States

Business Profits

  1. The business profits of an enterprise of a Contracting State shall be taxable only in that 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 business profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment.

  2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on 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 business profits which it might be expected to make if it were a distinct and independent enterprise engaged in the same or similar activities under the same or similar conditions.

  1. In determining the business profits of a permanent establishment, there shall be allowed as deductions expenses which are reasonably allocable to the income of that permanent establishment whether incurred in the State in which the permanent establishment is situated or elsewhere.

  2. No business profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise.

  3. For the purposes of the preceding paragraphs, the business 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.

  4. Where business profits include items of income which are dealt with separately in other Articles of this Convention, the provisions of those Articles shall, except as otherwise specifically provided therein, not be affected by the provisions of this Article.

  5. For the purposes of this Convention "business profits" means income derived from the conduct of any trade or business including the rental of tangible personal (movable) property and the furnishing of the personal services of another person, but not including income from the rental or licensing of cinematograph films or films or tapes used for radio or television broadcasting and not including income derived by an individual from the performance of personal services either as an employee or in an independent capacity.

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▸Contents — U.S. Income Tax Treaty — Jamaica Income Tax Treaty - 1980
U.S. Income Tax Treaty — Jamaica Income Tax Treaty - 1980

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