S.L. 123.65 Art. 7State controls State, or a permanent company a 1. property may be taxed 2. The the law of the term shall in and equipment respecting variable or or to explore and aircraft 3. The use, letting, or 4. The immovable for the 1. The that State through a business as only so much 2. Contracting State carri

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. A 6 RTICLE

INCOME FROM IMMOVABLE PROPERTY

Income derived by a resident of a Contracting State from immovable (including income from agriculture) situated in the other Contracting State 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, rights to which the provisions of general law landed property apply, usufruct of immovable property and rights to fixed payments as consideration for the working of, or the right to work, for, mineral deposits, sources and other natural resources; ships, boats shall not be 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.

Notwithstanding the provisions of paragraph 1, where an enterprise of a State which has a permanent establishment in the other Contracting on business activities in that other State otherwise than through the establishment, of the same or similar kind as the business activities the permanent establishment, then the profits of such activities may be the permanent establishment unless the enterprise shows that such could not have been reasonably undertaken by the permanent

Subject to the provisions of paragraph 4, 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 which are incurred for the purposes of the establishment, including executive and general administrative expenses whether in the Contracting State in which the permanent establishment elsewhere. as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the apportionment of the total profits of the enterprise to its various parts, paragraph 3 shall preclude that Contracting State from determining the taxed by such an apportionment as may be customary; the method of adopted shall, however, be such that the result shall be in accordance principles contained in this Article.