S.L. 123.104 Art. 6the provisions and carries on extraction or State shall be in that other therein, 30 days in of this is related to as part of the on by the on by both 30 days, then activities for a b) 7. An permanent other State insures risks 8. An Contracting broker, provided that However, on behalf of status with

Notwithstanding the preceding provisions of this Article and of Article 14, a person who is a resident of a Contracting State activities in connection with preliminary surveys, exploration, exploitation of natural resources situated in the other Contracting deemed to be carrying on in respect of those activities a business Contracting State through a permanent establishment or a fixed base situated unless such activities are carried on for a period or periods not exceeding the aggregate in any twelve-month period. However, for the purposes paragraph: a) where an enterprise carrying on activities in the other State another enterprise and that other enterprise continues same project the same activities that are or were being carried first-mentioned enterprise, and the activities carried enterprises exceed - when added together - a period of each enterprise shall be deemed to be carrying on its period exceeding 30 days in a twelve-month period; two enterprises shall be deemed to be related if one is controlled directly or indirectly by the other, or both are controlled directly or indirectly by a third person. insurance enterprise of a Contracting State shall be deemed to have a establishment in the other Contracting State if it collects premiums in that through an agent - other than an agent to whom paragraph 8 applies - or situated in that other State through such an agent. enterprise shall not be deemed to have a permanent establishment in a State merely because it carries on business in that State through a general commission agent or any other agent of an independent status such persons are acting in the ordinary course of their business. when the activities of such an agent are devoted wholly or almost wholly that enterprise, he will not be considered an agent of an independent the meaning of this paragraph.

fact that a company which is a resident of a Contracting State controls controlled by a company which is a resident of the other Contracting State, or on business in that other State (whether through a permanent or otherwise), shall not of itself constitute either company a establishment of the other.

CHAPTER III TAXATION OF INCOME Article 6

INCOME FROM IMMOVABLE PROPERTY Income derived by a resident of a Contracting State from immovable (including income from agriculture or forestry) situated in the other State may be taxed in that other State.

term "immovable property" shall have the meaning which it has under Contracting State in which the property in question is situated. The any case include property accessory to immovable property, livestock used in agriculture and forestry, rights to which the provisions of respecting landed property apply, usufruct of immovable property and variable or fixed payments as consideration for the working of, or the right mineral deposits, sources and other natural resources. Ships, boats and not be regarded as immovable property.

provisions of paragraph 1 shall apply to income derived from the direct use in any other form of immovable property.

provisions of paragraphs 1 and 3 shall also apply to the income from property of an enterprise and to income from immovable property used performance of independent personal services. Article 7

BUSINESS PROFITS profits of an enterprise of a Contracting State shall be taxable only in unless the enterprise carries on business in the other Contracting State permanent establishment situated therein. If the enterprise carries on aforesaid, the profits of the enterprise may be taxed in the other State but of them as are attributable to that permanent establishment. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State permanent establishment situated therein, there shall in each Contracting attributed to that permanent establishment the profits which it might make if it were a distinct and separate enterprise engaged in the same activities under the same or similar conditions and dealing wholly with the enterprise of which it is a permanent establishment.