S.L. 123.67 Art. 3from the direct 4. Where entitles the property held other form of the immovable 5. 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, is situated or 4. Insofar profit

The provisions of paragraph 1 shall apply to income derived use, letting, or use in any other form of immovable property. the ownership of shares or other corporate rights in a company owner of such shares or corporate rights to the enjoyment of immovable by the company, the income from the direct use, letting, or use in any such right to enjoyment may be taxed in the Contracting State in which property is situated. provisions of paragraphs 1, 3 and 4 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 Contracting State in which the permanent establishment elsewhere.

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 Convention, then the provisions of those Articles shall not be provisions of this Article. Nothing in this Article shall prevent a Contracting State from applying its the taxation of any person who carries on the business of insurance. Article 8 SHIPPING AND AIR TRANSPORT