Paragraph 6

This paragraph applies where the non-resident company provides the permanent establishment with goods or services.

If the goods or services are of a kind that the company supplies, in the ordinary course of its business, to third parties dealing with it at arm’s length, the matter is dealt with as a transaction to which the separate enterprise principle applies.

If not, the matter is dealt with as an expense incurred by the non-resident company for the purposes of the permanent establishment.