S.L. 123.6 Art. 3from the direct use, letting, or 4. The immovable for the 1. The that State through a business as only so much 2. Contracting permanent attributed to make if it activities with the 3. In allowed as permanent so incurred, elsewhere. 4. Insofar profits to be apportionment paragraph 2 taxed by such ado

The provisions of paragraph 1 shall apply to income derived 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. 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 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 shall preclude that Contracting State from determining the profits to be an apportionment as may be customary; the method of apportionment however, be such that the result shall be in accordance with the contained in this Article.

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 good and sufficient reason to the contrary. profits include items of income which are dealt with separately in of this Agreement, then the provisions of those Articles shall not be provisions of this Article.

Article 8 SHIPPING AND AIR TRANSPORT

from the operation of ships or aircraft in international traffic shall be in the Contracting State in which the place of effective management of is situated. purposes of this Article the term "profits from the operation of ships international traffic" shall include profits from: a) the occasional chartering of ships or aircraft, and b) the use or hiring out of containers (including trailers equipment used for transporting the containers), if these activities pertain to the operation of ships or aircraft in international