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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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DT: Grenada: double taxation agreement, Article 3: Industrial or commercial profits

(1) The industrial or commercial profits of a United Kingdom enterprise shall not besubject to Grenada tax unless the enterprise is engaged in trade or business in Grenadathrough a permanent establishment situated therein. If it is so engaged, tax may beimposed on those profits by Grenada but only on so much of them as it attributable to thatpermanent establishment.

(2) The industrial or commercial profits of a Grenada enterprise shall not be subject toUnited Kingdom tax unless the enterprise is engaged in trade or business in the UnitedKingdom through a permanent establishment situated therein. If it is so engaged, tax maybe imposed on those profits by the United Kingdom, but only on so much of them as isattributable to that permanent establishment.

(3) Where an enterprise of one of the territories is engaged in trade or business in theother territory through a permanent establishment situated therein, there shall beattributed to that permanent establishment the industrial or commercial profits which itmight be expected to derive from its activities in that other territory if it were anindependent enterprise engaged in the same or similar activities under the same or similarconditions and dealing at arm’s length with the enterprise of which it is a permanentestablishment.

(4) No portion of any profits arising from the sale of goods or merchandise by anenterprise of one of the territories shall be attributed to a permanent establishmentsituated in the other territory by reason of the mere purchase of the goods or merchandisewithin that other territory.