S.L. 123.77 Art. 7where a person 8 applies - is Contracting in the first- that person State or on behalf stock of goods for State, or for such it or have a (d) in 8. An permanent business in or any other the ordinary are devoted made between conditions, he meaning of 9. The or is controlled which carries permanent a

Notwithstanding the provisions of paragraphs 1 and 2 above, - other than an agent of an independent status to which paragraph acting in a Contracting State on behalf of an enterprise of the other State, that enterprise shall be deemed to have a permanent establishment mentioned Contracting State, in respect of any activities which undertakes for the enterprise, if -

(a) he has and habitually exercises in the first-mentioned Contracting a general authority to negotiate and conclude contracts for of such enterprise; or

(b) he maintains in the first-mentioned Contracting State a or merchandise from which he regularly sells goods or merchandise or on behalf of such enterprise; or

(c) he habitually secures orders in the first-mentioned Contracting exclusively or almost exclusively for the enterprise itself enterprise and other enterprises which are controlled by controlling interest in it; or so acting, he manufactures in that Contracting State for the enterprise goods or merchandise belonging to the enterprise. enterprise of a Contracting State shall not be deemed to have a establishment in the other Contracting State merely because it carries on that other Contracting State through a broker, general commission agent agent of an independent status, provided that such persons are acting in course of their business. However, when the activities of such an agent wholly or almost wholly on behalf of that enterprise and the transactions that agent and the enterprise are not made under arm’s length will not be considered an agent of an independent status within the this paragraph.

fact that a company which is a resident of a Contracting State controls by a company which is a resident of the other Contracting State, or on business in that other Contracting State (whether through a establishment or otherwise), shall not of itself constitute either company establishment of the other.

Article 6 INCOME FROM IMMOVABLE PROPERTY Income derived by a resident of a Contracting State from immovable (including income from agriculture) situated in the other Contracting State in that other Contracting State. term "immovable property" shall have the meaning which it has under Contracting State in which the property in question is situated. The any case include property accessory to immovable property, livestock used in agriculture, rights to which the provisions of general law landed property apply, usufruct of immovable property and rights to fixed payments as consideration for the working of, or the right to work, for, mineral deposits, sources and other natural resourcesg ships and not be regarded as immovable property. provisions of paragraph 1 shall also apply to income derived from the letting or 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 Contracting State unless the enterprise carries on business in the other State through a permanent establishment situated therein. If the carries on business as aforesaid, the profits of the enterprise may be taxed Contracting State but only so much of them as is attributable to that 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 with the enterprise of which it is a permanent establishment or with other enterprises with which it deals.