S.L. 123.135 Art. 4the term or delivery belonging to the delivery; belonging to the enterprise; the purpose of for the the purpose of a preparatory or 5. other than an on behalf of an an authority to be deemed to activities which such person are through a fixed permanent 6. An Contracting broker, general provided that

Notwithstanding the preceding provisions of this Article, "permanent establishment" shall be deemed not to include:

(a) the use of facilities solely for the purpose of storage, display of goods or merchandise belonging to the enterprise;

(b) the maintenance of a stock of goods or merchandise enterprise solely for the purpose of storage, display or

(c) the maintenance of a stock of goods or merchandise enterprise solely for the purpose of processing by another

(d) the maintenance of a fixed place of business solely for purchasing goods or merchandise or of collecting information, enterprise;

(e) the maintenance of a fixed place of business solely for carrying on, for the enterprise, any other activity of auxiliary character; combination is of a preparatory or auxiliary character. Notwithstanding the provisions of paragraphs 1 and 2, where a person -agent of an independent status to whom paragraph 6 applies - is acting enterprise and has, and habitually exercises, in a Contracting Party conclude contracts in the name of the enterprise, that enterprise shall have a permanent establishment in that Party in respect of any that person undertakes for the enterprise, unless the activities of limited to those mentioned in paragraph 4 which, if exercised place of business, would not make this fixed place of business a establishment under the provisions of that paragraph. enterprise shall not be deemed to have a permanent establishment in a Party merely because it carries on business in that Party through a commission agent or any other agent of an independent status, persons are acting in the ordinary course of their business. that a company which is a resident of a Contracting Party controls by a company which is a resident of the other Contracting Party, or business in that other Party (whether through a permanent or otherwise), shall not of itself constitute either company a establishment of the other. Article 6

Income from Immovable Property derived by a resident of a Contracting Party from immovable (including income from agriculture or forestry) situated in the other may be taxed in that other Party.

"immovable property" shall have the meaning which it has under Contracting Party in which the property in question is situated. The 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 or fixed payments as consideration for the working of, or the right deposits, quarries, sources and other natural resources; ships and be regarded as immovable property.

property or right referred to in paragraph 2 shall be regarded as situated standing timber, mineral deposits, quarries, sources or natural case may be, are situated or where the working may take place. provisions of paragraph 1 shall apply to income derived from the direct in any other form of immovable property. provisions of paragraphs 1 and 4 shall also apply to the income from property of an enterprise. Article 7

Business Profits profits of an enterprise of a Contracting Party shall be taxable only in the enterprise carries on business in the other Contracting Party permanent establishment situated therein. If the enterprise carries on Contracting Party carries on business in the other Contracting 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 activities under the same or similar conditions and dealing wholly with the enterprise of which it is a permanent establishment.