Artikel V

In the application of paragraph 3 of Article 7, no deduction shall be allowed in respect of amounts charged – otherwise than with respect to expenses actually incurred – by the head office of the enterprise or any of its other offices to the permanent establishment, by way of royalties, fees or other similar payments in return for the use of patents or other rights, or by way of commission, for specific services performed or for management, or except in the case of a banking enterprise, by way of interest on moneys made available to the permanent establishment likewise, no account shall be taken, in the determination of the profits of a permanent establishment, for such amounts charged – otherwise than with respect to expenses actually incurred – by the permanent establishment to the head office of the enterprise or any of its other offices.