S.L. 123.37 Art. 8State controls State, or a permanent company a 2. The term the law of the term shall in any and equipment general law rights to variable to work or to ships, boats and 3. The use, letting, or 4. The immovable for the 1. The that State unless through a business as only so much of 2. Subject Contracti

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.

ARTICLE 6 "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 explore for, mineral deposits, sources and other natural resources; 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 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 or with other associated which it deals. determination of the profits of a permanent establishment, there shall deductions expenses of the enterprise, being expenses which are purposes of the permanent establishment (including executive and administrative expenses so incurred) and which would be deductible if the establishment were an independent entity which paid those expenses, in the Contracting State in which the permanent establishment is elsewhere. in this Article shall affect the application of any law of a State relating to the determination of the tax liability of a person, determination of such liability by the exercise of discretion or the estimate by the competent authority of that State in cases in which, information available to the competent authority of that State, it is not practicable to ascertain the profits to be attributed to a permanent provided that that law shall be applied, and the result shall be in the principles contained in this Article. profits shall be attributed to a permanent establishment by reason of the unless there is good and sufficient reason to the contrary.