S.L. 123.46 Art. 5a permanent or installed by, with the

An enterprise of a Contracting State shall be deemed to have establishment in the other Contracting State if, for more than nine months:

(a) substantial equipment is in that other State being used for or under contract with, the enterprise;

(b) it carries on supervisory activities in that State in connection use of equipment referred to in sub-paragraph (a).