25. Where a person carries on a business through a permanent establishment of the person in Québec and through another permanent establishment of the person outside Québec,(1) any transfer of movable property or rendering of a service by the permanent establishment in Québec to the permanent establishment outside Québec is deemed to be a supply of the property or service; and
(2) in respect of that supply, the permanent establishments are deemed to be separate persons who deal with each other at arm’s length.