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1’Business profit’ means income derived by an enterprise from the conduct of a trade or business including income derived by an enterprise from providing or furnishing services. The double taxation agreements in defining ‘industrial or commercial profit’ draw a sharp distinction between profits from a business (business profits) on the one hand and the income in the form of dividends interest, rents and so forth (investment income) on the other. The agreements deal with it quite separately. So far business profits are concerned, they are taxable only if the enterprise has a permanent establishment in the State and only on the amounts which are attributable to that establishment.
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