S.L. 123.144 Art. 7State controls 1. Income property Contracting State 2. The the law of the term shall in any and equipment general law rights to variable to work, mineral aircraft shall not 3. The use, letting, or 4. The immovable 1. The that State unless through a business as only so much of 2. Subject Contracting

The fact that a company which is a resident of a Contracting CHAPTER III

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. term "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, boats and 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. 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 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 State in which the permanent establishment is situated or 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 Article 8

SHIPPING AND AIR TRANSPORT