(1) The industrial or commercial profits of a United Kingdom
enterprise shall not be subject to Grenada tax unless the
enterprise is engaged in trade or business in Grenada through a
permanent establishment situated therein. If it is so engaged, tax
may be imposed on those profits by Grenada but only on so much of
them as it attributable to that permanent establishment.
(2) The industrial or commercial profits of a Grenada
enterprise shall not be subject to United Kingdom tax unless the
enterprise is engaged in trade or business in the United Kingdom
through a permanent establishment situated therein. If it is so
engaged, tax may be imposed on those profits by the United Kingdom,
but only on so much of them as is attributable to that permanent
establishment.
(3) Where an enterprise of one of the territories is engaged
in trade or business in the other territory through a permanent
establishment situated therein, there shall be attributed to that
permanent establishment the industrial or commercial profits which
it might be expected to derive from its activities in that other
territory if it were an independent enterprise engaged in the same
or similar activities under the same or similar conditions and
dealing at arm's length with the enterprise of which it is a
permanent establishment.
(4) No portion of any profits arising from the sale of goods
or merchandise by an enterprise of one of the territories shall be
attributed to a permanent establishment situated in the other
territory by reason of the mere purchase of the goods or
merchandise within that other territory.
