S.L. 123.45 ст. 7to have a it carries on or any other in the ordinary are devoted between that agent and be considered paragraph. 8. The or is controlled which carries establishment permanent 1. property Contracting 2. The the law of the term shall in and equipment general law and rights to right to work, resources.

An enterprise of a Contracting State shall not be deemed permanent establishment in the other Contracting State merely because business in that other State through a broker, general commission agent agent of an independent status, provided that such persons are acting course of their business. However, when the activities of such an agent wholly or almost wholly on behalf of that enterprise and the transactions the enterprise are not made under arm’s length conditions, he will not an agent of an independent status within the meaning of this fact 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 III

TAXATION OF INCOME

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 immovable property apply, usufruct of immovable property variable or fixed payments as consideration for the working of, or the or to explore for, mineral deposits, sources and other natural Ships, boats and aircraft 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.

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 allowed as deductions expenses which are incurred for the purposes permanent establishment, including executive and general administrative so incurred, whether incurred in the Contracting State in which establishment is situated or elsewhere.