S.L. 123.110 Art. 8State controls 1. Income property Contracting State 2. The term the law of the term shall in any and equipment general law rights to variable to work, mineral shall not be 3. The use, letting or use 4. The immovable for the 1. The that State unless through a business as only so much of 2. Subject Co

The fact that a company which is a resident of a Contracting 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 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 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. determination of the profits of a permanent establishment, there shall 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 which are allowed under the provisions of the domestic law of the in which the permanent establishment is situated. 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