Article 7 Business Profits

1) Profits of an enterprise of a Contracting State under are never taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, profits of the enterprise may be taxed in that other State but only to the extent they are attributable to that permanent establishment.

2) If an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establishment is situated therein shall, subject to the provisions of paragraph 3 of each Contracting State a permanent establishment the profits which would have been able to achieve if it were a separate company engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which the permanent establishment.

3) In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establishment including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere.

4) If in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by the usual division, the method of apportionment adopted shall, however, be such that the result was in accordance with the principles set out in this article.

5) Permanent establishment neprictou any profits from the fact that the mere purchase of goods for the enterprise.

6) the profits to be attributed to the permanent establishment for purposes of the preceding paragraphs the same way every year unless there is sufficient reason to the contrary.

7) Where profits include items of income which are dealt with separately in other Articles of this Agreement, provisions of those Articles shall not be affected by the provisions of this article.