S.L. 123.52 Art. 4in a company of immovable or use in any for the 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. 4. Insofar profits to be apportionment parag

Where the ownership of shares or other corporate rights entitles the owner of such shares or corporate rights to the enjoyment property held by the company, the income from the direct use, letting, performance of independent personal services.

Article 7 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 theprofits 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 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, the profits to be attributed to establishment shall be determined by the same method year by year 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. Article 8 SHIPPING AND AIR TRANSPORT

of an enterprise of a Contracting State from the operation of ships or international traffic shall be taxable only in that State.

provisions of paragraph 1 shall also apply to profits from the a pool, a joint business or an international operating agency.