S.L. 123.151 Art. 5a person - - is acting State an shall be any activities of such person a fixed place of establishment 6. enterprise of have a in the territory other than an 7. An Contracting broker, provided that that in their made or 8. The or is controlled which carries establishment permanent 1. property Contrac

Notwithstanding the provisions of paragraphs 1 and 2, where other than an agent of an independent status to whom paragraph 7 applies on behalf of an enterprise and has, and habitually exercises, in a Contracting authority to conclude contracts in the name of the enterprise, that enterprise deemed to have a permanent establishment in that State in respect of which that person undertakes for the enterprise, unless the activities are limited to those mentioned in paragraph 4 which, if exercised through business, would not make this fixed place of business a permanent under the provisions of that paragraph. Notwithstanding the foregoing provisions of this Article, an insurance a Contracting State shall, except in regard to reinsurance, be deemed to permanent establishment in the other Contracting State if it collects premiums of that other State or insures risks situated therein through a person agent of an independent status to whom paragraph 7 applies. 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 and commercial or financial relations with the enterprise conditions are not imposed that differ from those generally agreed to by independent agents. fact that a company which is a resident of a Contracting State controls 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. 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. 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 is attributable to: that permanent establishment; sales in that other State of goods or merchandise of the same or similar kind as the goods or merchandise sold through that permanent establishment.

However, the profits derived from the sales described in subparagraph b) shall not be taxable in the other Contracting State if the enterprise demonstrates such sales have been carried out for reasons other than obtaining a benefit Convention.