S.L. 123.59 Art. 4income from property used for the 5. Where institution and a Contracting income from enjoyment by of Articles 7 1. The that State through a business as Contracting establishment. 2. Contracting permanent attributed to make if it activities with the enterprises 3. In allowed as permanent so incurred,

The provisions of paragraphs 1 and 3 shall also apply to the immovable property of an enterprise and to income from immovable performance of independent personal services. a person has shares or other rights in a company, trust or comparable is thereby entitled to the enjoyment of immovable property situated in State and held by that company, trust or comparable institution, the direct use, letting or use in any other form of that right of that person may be taxed in that State notwithstanding the provisions and 14. 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 only so much of them as is attributable to that permanent

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 or with other associated with which it deals. 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 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 purposes of the preceding paragraphs of this Article, the profits to be the 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 of this Convention, then the provisions of those Articles shall not be provisions of this Article.

provisions of this Article shall not affect the provisions of the law of a State regarding the taxation of profits from the business of insurance. Article 8 SHIPPING AND AIR TRANSPORT