S.L. 123.169 Art. 8State controls State, or a permanent company a 1. property Contracting 2. The the law of the term shall in and equipment general law rights to to work, shall not be 3. The use, letting or 4. The immovable for the 1. The that State through a business as only so much 2. Contracting permanent attribute

The fact that a company which is a resident of a Contracting or is controlled by a company which is a resident of the other Contracting which carries on business in that other State (whether through establishment or otherwise), shall not of itself constitute either permanent 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 and aircraft 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 is attributable to that permanent establishment. Subject 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 that permanent establishment the profits which it might be expected to were a distinct and separate enterprise engaged in the same or similar under 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 (other than expenses which would not be deductible permanent establishment were a separate enterprise of a Contracting State) incurred for the purposes of the permanent establishment, including general administrative expenses so incurred, whether in the State in permanent establishment is situated or elsewhere. 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 shall preclude that Contracting State from determining the profits to be an 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