Industrial and Commercial Profits [Internal Revenue] Law and Legal Definition
Pursuant to 26 CFR 509.104 (11) [Title 26 Internal Revenue; Chapter I Internal Revenue Service, Department of the Treasury; Subchapter G Regulations under Tax Conventions; Part 509 Switzerland; Subpart General Income Tax], the term Industrial and Commercial Profits means “profits arising from industrial, commercial, mercantile, manufacturing, and like activities of an enterprise, including mining, financial and insurance profits. It does not include income in the form of dividends, interests, rents, royalties, or remuneration for personal services. In determining the industrial and commercial profits from sources within the United States of a Swiss enterprise, no profits shall be deemed to arise from the more purchase of goods or merchandise within the United States by such enterprise. Moreover, in determining such profits of the United States permanent establishment of such enterprise, there shall be allowed as deductions all expenses which are reasonably applicable to the permanent establishment, including executive and general administrative expenses so applicable.”
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