S.L. 123.157 Art. 3from the direct 1. The that State unless through a business as only so much of 2. Subject Contracting permanent attributed to that make if it were activities under with the 3. In allowed as permanent so incurred, elsewhere. any, paid permanent offices, by way patents or other for management, moneys

The provisions of paragraph 1 shall apply to income derived use, letting, or use in any other form of immovable property. BUSINESS PROFITS

profits of an enterprise of a Contracting State shall be taxable only in 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 them as is attributable to that permanent establishment.

to the provisions of paragraph 3, where an enterprise of a State carries on business in the other Contracting State through a establishment situated therein, there shall in each Contracting State be permanent establishment the profits which it might be expected to a distinct and separate enterprise engaged in the same or similar the same or similar conditions and dealing wholly independently enterprise of which it is a permanent establishment. determining the profits of a permanent establishment, there shall be deductions expenses which are incurred for the purposes of the establishment, including executive and general administrative expenses whether in the State in which the permanent establishment is situated or However, no such deduction shall be allowed in respect of amounts, if (otherwise than towards reimbursement of actual expenses) by the establishment to the head office of the enterprise or any of its other of royalties, fees or other similar payments in return for the use of rights, or by way of commission, for specific services performed or or, except in the case of a banking enterprise, by way of interest on the permanent establishment. Likewise, no account shall be taken, in of the profits of a permanent establishment, for amounts charged towards reimbursement of actual expenses), by the permanent the head office of the enterprise or any of its other offices, by way or other similar payments in return for the use of patents or other of commission for specific services performed or for management, case of a banking enterprise, by way of interest on moneys lent to of the enterprise or any of its other offices.

as it has been customary in a Contracting State to determine the attributed to a permanent establishment on the basis of an of the total profits of the enterprise to its various parts, nothing in preclude that Contracting State from determining the profits to be apportionment as may be customary; the method of apportionment however, be such that the result shall be in accordance with the contained in this Article. profits shall be attributed to a permanent establishment by reason of the by that permanent establishment of goods or merchandise for the purposes of the preceding paragraphs of this Article, the profits to be permanent establishment shall be determined by the same method unless there is good and sufficient reason to the contrary. profits include items of income which are dealt with separately in this Convention, then the provisions of those Articles shall not be provisions of this Article.