S.L. 123.8 Art. 5the term or delivery belonging to the delivery; belonging to the enterprise; the purpose of for the the purpose of a preparatory or any combination that the on behalf of an authority to deemed to have which that are limited to place of establishment 7. An Contracting broker, general provided that 8.

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; f) the maintenance of a fixed place of business solely for of activities mentioned in sub-paragraphs a) to e), provided enterprise and has, and habitually exercises, in a Contracting State an conclude contracts in the name of the enterprise, that enterprise shall be a permanent establishment in that State in respect of any activities person undertakes for the enterprise, unless the activities of such person those mentioned in paragraph 5 which, if exercised through a fixed business, would not make this fixed place of business a permanent under the provisions of that paragraph.

enterprise shall not be deemed to have a permanent establishment in a State merely because it carries on business in that State through a commission agent or any other agent of an independent status, such persons are acting in the ordinary course of their business. 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. Chapter 3 Taxation of Income

Article 6 Income from Immovable Property derived by a resident of a Contracting State from immovable (including income from agriculture or forestry) situated in the other may be taxed in that other State. "immovable property" shall have the meaning which it has under Contracting State 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, 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. determination of the income from immovable property which a Contracting State has in the other Contracting State expenses (including claims) which are incurred for the purposes of such property shall be deductions on the same conditions as are provided for residents of that 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