Common use of BUSINESS PROFITS Clause in Contracts

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- said, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment situated therein, there shall in each Contracting State be attributed to that perma- nent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- ment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. The expenses to be allowed as deductions by a Contracting State shall include only expenses that are deductible under the domestic laws of that State. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only on so much of them thereof as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- ment, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State If the information available to the competent authority is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed determination of the tax liability of a person by such the exercise of a discretion or the making of an apportionment as may be customary; estimate by the method of apportionment adopted shallcompetent authority, however, be such provided that the result law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles contained in principle of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the that other Contracting State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the Contracting State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphsparagraphs of this Article, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only on so much of them thereof as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- ment, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State If the information available to the competent authority is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed determination of the tax liability of a person by such the exercise of a discretion or the making of an apportionment as may be customary; estimate by the method of apportionment adopted shallcompetent authority, however, be such provided that the result law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles contained in of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere, which are allowed under the provisions of the domestic law of the Contracting State in which the permanent establishment is situated. 4. Insofar In so far as it has been customary in a Contracting contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where Where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- ment, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State If the information available to the competent authority is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed determination of the tax liability of a person by such the exercise of a discretion or the making of an apportionment as may be customary; estimate by the method of apportionment adopted shallcompetent authority, however, be such provided that the result law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles contained in principle of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 76. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article. 7. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State Party shall be taxable only in that State Party unless the enterprise carries on business in the other Contracting State Party through a permanent establishment situated therein. If the enterprise carries on business as afore- saidaforesaid, the profits of the enterprise may be taxed in the other State Party but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State Party carries on business in the other Contracting State Party through a permanent establish- ment establishment situated therein, there shall in each Contracting State Party be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State Party in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State Party to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, or on the basis of such other method as may be prescribed by the laws of that Party, nothing in paragraph 2 shall preclude that Contracting State Party from determining the profits to be taxed by such an apportionment as may be customaryor other method; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere, which are allowed under the provisions of the domestic law of the Contracting State in which the permanent establishment is situated. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. (1. ) The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. (2. ) Subject to the provisions of paragraph 33 of this Article, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. (4. ) Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 of this Article shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. (5. ) No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. (6. ) For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. (7. ) Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- ment, establishment including executive and general administrative expenses so incurred, insofar as they are reasonably allowable to the permanent establishment, whether in the Contracting State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting contracting State from determining the profits to be taxed by such an apportionment as may be customary; the . The method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State Contracting State, but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. The expenses to be allowed as deductions by a Contracting State include only expenses that are deductible under the domestic laws of that State. The application of the provisions of the domestic law shall be in accordance with the principles contained in this paragraph. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the . The method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. (1. ) The profits of an enterprise of a Contracting State shall be taxable only in that Contracting 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other Contracting State but only so much of them as is attributable to that permanent establishment. (2. ) Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the Contracting State in which the permanent establishment is situated or elsewhere. (4. ) Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. (5. ) No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. (6. ) For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. (7. ) Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The industrial or commercial profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other Contracting State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere, notwithstanding any limitation domestic law, provided that the expenses are deducted in accordance with international practice. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes purpose of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 33 of this Article, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the business of the permanent establish- ment, establishment including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere, in accordance with the provisions of the taxation laws of that State. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the . The method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained embodied in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. (1. ) The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. (2. ) Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. (3. ) In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere, which are allowed under the provisions of the domestic law of the Contracting state in which the permanent establishment is situated. (4. ) Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. (5. ) No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. (6. ) For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. (7. ) Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only on so much of them thereof as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- ment, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State If the information available to the competent authority is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed determination of the tax liability of a person by such the exercise of a discretion or the making of an apportionment as may be customary; estimate by the method of apportionment adopted shallcompetent authority, however, be such provided that the result law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles contained in of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphsparagraphs of this Article, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. (1. ) The profits of an enterprise of a one of the Contracting State States shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. (2. ) Subject to the provisions of paragraph (3), where an enterprise of a one of the Contracting State States carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishmentestablishment or with other enterprises with which it deals. (3. ) In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses of the enterprise, being expenses which are incurred for the purposes of the permanent establish- ment, establishment (including executive and general administrative expenses so incurred) and which would be deductible if the permanent establishment were an independent entity which paid those expenses, whether incurred in the Contracting State in which the permanent establishment is situated or elsewhere. (4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. ) No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For (5) Nothing in this Article shall affect the purposes application of any law of a Contracting State relating to the determination of the preceding paragraphs, tax liability of a person in cases where the information available to the competent authority of that State is inadequate to determine the profits to be attributed to the a permanent establishment establishment, provided that that law shall be determined by applied, so far as the same method year by year unless there is good and sufficient reason information available to the contrarycompetent authority permits, consistently with the principles of this Article. 7. (6) Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article. (7) Nothing in this Article shall affect the operation of any law of a Contracting State relating to tax imposed on profits from insurance with non-residents provided that if the relevant law in force in either Contracting State at the date of signature of this Agreement is varied (otherwise than in minor respects so as not to affect its general character) the Contracting States shall consult with each other with a view to agreeing to any amendment of this paragraph that may be appropriate.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses of the enterprise which are incurred for the purposes of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. Insofar In so far as it has been customary in a Contracting State State, according to its law, to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained embodied in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where When profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The business profits of an enterprise a resident of a Contracting State shall be taxable only in that State unless the enterprise resident carries on or has carried on business in the other Contracting State through a permanent establishment situated therein. If the enterprise resident carries on or has carried on business as afore- saidaforesaid, the business profits of the enterprise resident may be taxed in the other State but only so much of them as is attributable to to: a) that permanent establishment; b) sales in that other State of goods or merchandise of the came kind as those sold through that permanent establishment; or c) other business activities carried on in that other State of the same kind as those effected through that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise a resident of a Contracting State carries on or has carried on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the business profits which it might sight be expected to make if it were a distinct and separate enterprise independent person engaged in the same or similar activities under the same or simi- lar conditions and dealing wholly independently with the enterprise of which it is a permanent establishmentsimilar conditions. 3. In determining the business profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establish- mentestablishment. There shall be allowed a reasonable allocation, including between a resident of a Contracting State and a permanent establishment of such resident situated in the other Contracting State, of properly documented expenses incurred for the purpose of the resident's business activities. Such allocable expenses include executive and general administrative expenses so incurredexpenses, research and development expenses, interest, and charges for management, consultancy, or technical assistance, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary The permanent establishment shall not be allowed a deduction for amounts paid to its head office or any of the other offices of the resident by way of royalties, fees or other similar payments in a Contracting State return for the use of patents or other rights, or by way of commission, for specific services performed or for management, or by way of interest on moneys lent to determine the permanent establishment. The business profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with determined by the principles contained in this Articlesame method year by year unless there is good and sufficient reason to the contrary. 54. No business profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterpriseresident. 5. Where the information available to or readily obtainable by the competent authority of a Contracting State is not adequate to determine the expenses of a permanent establishment, profits may be calculated in accordance with the tax laws of that State. For purposes of this paragraph 5, information will be considered to be readily obtainable if the taxpayer provides the information to the requesting competent authority within 91 days of a written request by the competent authority for such information. 6. For the purposes of the preceding paragraphsthis Article, the term "business profits" means profits to be attributed to derived from the permanent establishment shall be determined active conduct of business. It includes, for example, profits from manufacturing, mercantile, transportation, communication, or extractive activities, and from the furnishing of services of another person. It does not include income received by an individual for his performance of personal services (either as an employee or in an independent capacity) Income of an individual from the same method year by year unless there performance of services as an employee is good and sufficient reason to dealt with in Article 15 (Income from Employment). Income of an individual from the contraryperformance of services in an independent capacity is dealt with in Article 14 (Independent Personal Services). 7. Where business profits include items of income which are dealt with separately in other Articles of this the Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the that other Contracting State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishmentestablishment or with other enterprises with which it deals. 3. In determining the profits of a permanent establishment, there shall be allowed as deductions expenses of the enterprise, being expenses which are incurred for the purposes of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, and which would be deductible if the permanent establishment were an independent enterprise which paid those expenses, whether incurred in the Contracting State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary Nothing in this Article shall affect the application of any law of a Contracting State relating to the determination of the tax liability of a person in cases where the information available to the competent authority of that Contracting State is inadequate to determine the profits to be attributed to a permanent establishment establishment, provided that, on the basis of an apportionment the available information, the determination of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance permanent establishment is consistent with the principles contained stated in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphsparagraphs of this Article, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income or gains which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article. 8. Nothing in this Article shall affect the application of any law of a Contracting State relating to tax imposed on profits from insurance with a person other than a resident of that Contracting State.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentall expenses, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the Contracting State in which the permanent establishment is situated or elsewhere. However, no such deduction shall be allowed in respect of such amounts, if any, paid (otherwise than towards reimbursement of actual expenses) by the permanent establishment to the head office of the enterprise or any of its other offices, by way of royalties, fees or other similar payments in return for the use of patents or other rights, by way of commission, for specific services performed or for management, or, except in the case of a banking enterprise, by way of interest on moneys lent to the permanent establishment. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The business profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the business profits of the enterprise may be taxed in the other State but only so much of them as is are attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the business profits which that it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the business profits of a permanent establishment, there shall be allowed as deductions necessary expenses which that are incurred for the purposes of the permanent establish- mentestablishment, including a reasonable allocation of executive and general administrative expenses, research and development expenses, interest, and other expenses so incurredincurred for the purposes of the enterprise as a whole (or the part thereof which includes the permanent establishment), whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No business profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 65. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 76. Where business profits include items of income which that are dealt with separately in other Articles of this the Convention, then the provisions of those Articles shall not be affected by the provisions of this Article. 7. Any income or gain attributable to a permanent establishment or fixed base during its existence is taxable in the Contracting State where such permanent establishment or fixed base is situated even if the payments are deferred until such permanent establishment or fixed base has ceased to exist. 8. Notwithstanding the provisions of paragraph 1, in the absence of a permanent establishment, the United States may impose its excise tax on insurance premiums paid to foreign insurers and Chile may impose its tax on payments for insurance policies contracted with foreign insurers. However, notwithstanding the provisions of Article 2 (Taxes Covered), the tax so charged shall not exceed:

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only on so much of them thereof as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph (3), where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- ment, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State If the information available to the competent authority is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed determination of the tax liability of a person by such the exercise of a discretion or the making of an apportionment as may be customary; estimate by the method of apportionment adopted shallcompetent authority, however, be such provided that the result law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles contained in principle of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article. 8. Nothing in this Article shall apply to either Contracting State to prevent the operation in the Contracting State of any provisions of its law at any time in force relating to the taxation of any income from the business of any form of insurance. Provided that if the law in force in either Contracting State at the date of signature of this Agreement relating to the taxation of that income is varied (otherwise than in minor respects so as not to affect its general character), the Contracting States shall consult with each other with a view to agreeing to such amendment of this paragraph as may be appropriate.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to to: (a) that permanent establishment; or (b) sales within that other Contracting State of goods or merchandise of the same or a similar kind as those sold through that permanent establishment; or (c) other business activities carried on in that other State of the same or similar kind as those effected through that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate independent enterprise engaged in the same or similar activities under the same game or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the profits of a permanent establishment, there shall be allowed as deductions expenses expenses, which are incurred for the purposes of the permanent establish- mentestablishment, including an allocation of executive and general administrative expenses so incurredincurred for the purposes of the enterprise as a whole, whether in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 5. Nothing in this Article shall affect the application of any law of a Contracting State relating to the determination of the tax liability of a person in cases where the information available to the competent authority of that State is inadequate to determine the profits to be attributed to a permanent establishment, provided that the law shall be applied, so far as the information available to the competent authority permits. consistent with the principles of this Article. 6. Where profits include items of income which are dealt with separately in other Articles of this Agreement, then the provisions of those Articles shall not be affected by the provisions of this Article. 7. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same swne method year by year unless there is good and sufficient reason to the contrary. 78. Where Nothing in this Article shall affect the operation of: (a) any law of a Contracting State relating to tax imposed on profits include items from insurance with non-residents; or (b) the law of Papua New Guinea relating to the taxation of income which are dealt derived by a foreign contractor from a prescribed contract, where, in accordance with separately this Agreement, that contractor is a resident of Fiji with a permanent establishment in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this ArticlePapua New Guinea.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. Such deductions shall be determined in accordance with domestic law. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those these Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated thereinin that other Contracting State. If the enterprise carries on or has carried on business as afore- saidaforesaid, the profits of the enterprise may be taxed in the other Contracting State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the profits of a permanent establishment, there shall be allowed as deductions those deductible expenses which are incurred for the purposes of the permanent establish- mentestablishment, including a reasonable allocation of executive and general administrative expenses so incurred, whether in the Contracting State in which the permanent establishment is situated or elsewhere, taking into consideration the applicable national legislation of that Contracting State. 4. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 5. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes purpose of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income or gains which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall only be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to : (a) that permanent establishment ; (b) sales in that other State of goods or merchandise of the same or similar kind as those sold through that permanent establishment ; or (c) other business activities carried on in that other State of the same or similar kind as those effected through that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 business of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of a certain percentage of the gross receipt of the enterprise or of the permanent establishment or on the basis of an apportionment of the total profits of the enterprise to its various parts, after exhausting all internal procedures required by law, nothing in the paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment a method as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that the permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is a good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits Profits of an enterprise of a one of the Contracting State States shall be 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 afore- said, aforesaid the profits of the enterprise may be taxed in the other State State, but only so much of them as is attributable to to: (a) that permanent establishment; or (b) sales within that other Contracting State of goods or merchandise of the same or a similar kind as those sold, or other business activities of the same or a similar kind as those carried on, through that permanent establishment if the sale or the business activities had been made or carried on in that way with a view to avoiding taxation in that other State. 2. Subject to the provisions of paragraph 3, where an enterprise of a one of the Contracting State carries States carried on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishmentestablishment or with other enterprises with which it deals. 3. In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses of the enterprise, being expenses which are incurred for the purposes of the permanent establish- ment, establishment (including executive and general administrative expenses so incurred) and which would be deductible if the permanent establishment were an independent entity which paid those expenses, whether incurred in the Contracting State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 65. For If the purposes information available to the taxation authority of the preceding paragraphs, a Contracting State is inadequate to determine the profits to be attributed to the permanent establishment of an enterprise, nothing in this Article shall affect the application of any law of that State relating to the determination of the tax liability of a person provided that that law shall be determined by applied, so far as the same method year by year unless there is good and sufficient reason information available to the contrarytaxation authority permits, consistently with the principles of this Article. 76. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article. 7. The profits of an enterprise of one of the Contracting States from the carrying on in the other Contracting State of a business of any form of insurance may be taxed in the other Contracting State in accordance with the law of that other State relating specifically to the taxation of any person who carries on such business, and Article 24 shall apply for the elimination of double taxation as if the profits so taxed were attributable to a permanent establishment of the enterprise in the State imposing the tax.

BUSINESS PROFITS. 1. The profits of an enterprise of a one of the Contracting State States shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State State, but only so much of them as is attributable to — (a) that permanent establishment; or (b) sales within that other Contracting State of goods or merchandise of the same or a similar kind as those being sold, or other business activities of the same or a similar kind as those being carried on through that permanent establishment if the sale or the business activities had been made or carried on in that way with a view to avoiding taxation in that other State. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. Notwithstanding the provisions of paragraph 3, no deduction shall be allowed in respect of amounts paid or charged (other than reimbursement of actual expenses) by the permanent establishment to the head office of the enterprise or any of its other offices, by way of: (a) royalties, fees or other similar payments in return for the use of patents or other rights; (b) commission for specific services performed or for management; and (c) interest or money lent to the permanent establishment, except in the case of a banking institution. 6. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 67. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 78. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- ment, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State If the information available to the competent authority is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed determination of the tax liability of a person by such the exercise of a discretion or the making of an apportionment as may be customary; estimate by the method of apportionment adopted shallcompetent authority, however, be such provided that the result law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles contained in principle of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only on so much of them thereof as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- ment, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State If the information available to the competent authority is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed determination of the tax liability of a person by such the exercise of a discretion or the making of an apportionment as may be customary; estimate by the method of apportionment adopted shallcompetent authority, however, be such provided that the result law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles contained in principle of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other Contracting State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. The expenses to be allowed as deductions by a Contracting State include only expenses that are deductible under the domestic laws of that State. The application of the provisions of the domestic law shall be in accordance with the principles contained in this paragraph. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the . The method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article. 8. Nothing in this Article shall prevent a Contracting State from applying its law relating to the taxation of any person who carries on the business of insurance.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only on so much of them thereof as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- ment, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar In so far as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 3 shall preclude that Contracting the State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, however be such that the result shall will be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. (1. ) The profits of an enterprise of a Contracting State shall be 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 in business as afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is directly or indirectly attributable to that permanent establishment. (2. Subject to the provisions of paragraph 3, where ) Where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. (3. ) In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establish- mentestablishment, including a reasonable allocation of executive and general administrative expenses so incurredincurred for the purpose of the enterprise as a whole, whether in the Contracting State in which the permanent establishment is situated or elsewhere. (4. ) Insofar as it has been customary in a Contracting State State, according to its law, to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 (2) of this Article shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained principle laid down in this Article. (5. ) No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. (6. ) For the purposes purpose of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. (7. ) Where profits include items of income which are dealt with separately in other Articles Article of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the that other Contracting State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 33 of this Article, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the Contracting State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 of this Article shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphsparagraphs of this Article, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where Where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. In any case, where the correct amount of profits attributable to a permanent establishment is incapable of determination or the ascertaining thereof presents exceptional difficulties, the profits attributable to the permanent establishment may be computed on a reasonable basis. 3. In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establish- ment, establishment including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere, but this does not include any expenses which, under the law of that State, would not be allowed to be deducted by an enterprise of that State. 4. Insofar In so far as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained laid down in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 76. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article. 7. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State States through a permanent establishment situated therein. If the enterprise carries on business as afore- saidaforesaid, the profits of for the enterprise may be taxed in the other State but only so much of them thereof as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- ment, including executive and general administrative expenses so incurredwhich would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State If the information available to the competent authority is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed determination of the tax liability of a person by such making an apportionment as may be customary; the method of apportionment adopted shallestimate, however, be such provided that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them thereof as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. Such deductions shall be determined in accordance with the taxation law of that State. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. If the information available to the competent authority is inadequate to determine the profits to be attributed to the permanent establishment of an enterprise, nothing in this Article shall affect the application of any law of that State relating to the determination of the tax liability of a person by the exercise of a discretion or the making of an estimate by the competent authority, provided that the law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles of this Article. 6. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 67. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 78. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- ment, including executive and general administrative expenses expenses, which would be deductible if the permanent establishment were an independent enterprise, in so incurredfar they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State If the information available to the competent authority is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed determination, of the tax liability of a person by such the exercise of a discretion or the making of an apportionment as may be customary; estimate by the method of apportionment adopted shallcompetent authority, however, be such provided that the result law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles contained in principle of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is directly or indirectly attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. In any case where the correct amount of profits attributable to a permanent establishment is incapable of determination or the determination thereof presents exceptional difficulties, the profits attributable to the permanent establishment may be estimated on a reasonable basis. 3. In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the business of the permanent establish- ment, establishment including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere, in accordance with the provisions of and subject to the limitations of the taxation laws of that State. 4. Insofar as it has been customary in a the Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article. 8. For the purpose of paragraph 1, the term "directly or indirectly attributable to the permanent establishment" includes profits arising from transactions in which the permanent establishment has been involved and such profits shall be regarded as attributable to the permanent establishment to the extent appropriate to the part played by the permanent establishment in those transactions, even if those transactions are made or placed directly with the overseas head office of the enterprise rather than with the permanent establishment.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State Party shall be taxable only in that State Party unless the enterprise carries on business in the other Contracting State Party through a permanent establishment situated therein. If the enterprise carries on business as afore- saidaforesaid, the profits of the enterprise may be taxed in the other State Party, but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State Party carries on business in the other Contracting State Party through a permanent establish- ment establishment situated therein, there shall in each Contracting State Party be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State Party in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State Party to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, or on the basis of such other method as may be prescribed by the laws of that Party, nothing in paragraph 2 shall preclude that Contracting State Party from determining the profits to be taxed by such an apportionment as may be customaryor other method; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 or has carried on business as afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions those deductible expenses which are incurred for the purposes of the permanent establish- ment, establishment including executive and general administrative expenses so incurredexpenses, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 5. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 6. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a one of the Contracting State States shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a one of the Contracting State States carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishmentestablishment or with other enterprises with which it deals. 3. In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses of the enterprise, being expenses which are incurred for the purposes of the permanent establish- ment, establishment (including executive and general administrative expenses so incurred) and which would be deductible if the permanent establishment were an independent entity which paid those expenses, whether incurred in the Contracting State in which the permanent establishment is situated or elsewhere. 4. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 5. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Nothing in this Article shall affect the application of any law of a Contracting State relating to the determination of the tax liability of a person in cases where the information available to the competent authority of that State is inadequate to determine the profits to be attributed to a permanent establishment, provided that that law shall be applied, so far as the information available to the competent authority permits, consistently with the principles of this Article. 8. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article. 9. Nothing in this Article shall affect the operation of: (a) any law of Papua New Guinea in so far as it relates to the tax chargeable on that part, deemed to be taxable income, of an insurance premium paid to an enterprise of Singapore, provided that the tax rate applied to such income shall not exceed the rate which would be imposed on the income of a corporation resident in Papua New Guinea and carrying on an insurance business; or (b) the law of Papua New Guinea relating to: (i) the specific gains tax upon taxable specific gains; or (ii) the taxation of income derived by a foreign contractor from a prescribed contract within the meaning of that law, where, in accordance with this Agreement, that contractor is a resident of Singapore with a permanent establishment in Papua New Guinea, provided that if the relevant law in force in either Contracting State at the date of signature of this Agreement is varied (otherwise than in minor respects so as not to affect its general character) the Contracting States shall consult with each other with a view to agreeing to any amendment of this paragraph that may be appropriate.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is directly or indirectly attributable to that permanent establishment. 2. Subject to the provisions of paragraph 33 of this Article, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the business of the permanent establish- ment, establishment including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of a certain reasonable percentage of the gross receipts of the enterprise or on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that such Contracting State from determining the profits to be taxed by any of such an apportionment as may be customarymethods; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained laid down in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 6. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article. 8. For the purpose of paragraph 1, the term "directly or indirectly attributable to the permanent establishment" includes profits arising from transactions in which the permanent establishment has been involved and such profits shall be regarded as attributable to the permanent establishment to the extent appropriate to the part played by the permanent establishment in those transactions, even if those transactions are made or placed directly with the overseas head office of the enterprise rather than with the permanent establishment.

BUSINESS PROFITS. 1. The profits of an enterprise of a one of the Contracting State States shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State State, but only so much of them as is attributable to - a) that permanent establishment; or b) sales within that other Contracting State of goods or merchandise of the same or a similar kind as those being sold, or other business activities of the same or a similar kind as those being carried on through that permanent establishment if the sale or the business activities had been made or carried on in that way with a view to avoiding taxation in that other State. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. Notwithstanding the provisions of paragraph 3, no deduction shall be allowed in respect of amounts paid or charged (other than reimbursement of actual expenses) by the permanent establishment to the head office of the enterprise or any of its other offices, by way of: a) royalties, fees or other similar payments in return for the use of patents or other rights; b) commission for specific services performed or for management; and c) interest or money lent to the permanent establishment, except in the case of a banking institution. 6. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 67. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 78. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is directly or indirectly attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, 3 of this Article where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In the determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establish- ment, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State If the information available to the competent authority is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed determination of the tax liability of a person by such the exercise of a discretion or the making of an apportionment as may be customary; estimate by the method of apportionment adopted shallcompetent authority, however, be such provided that the result law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles contained in of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State State, but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where 3,where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 business of the permanent establish- mentestablishment, including executive and general general: administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. The permanent establishment shall not be allowed a deduction for amounts paid to its head office or any of the other office of the resident by way of royalties, fees or other similar payment in return for the use of patents or other rights, or by way of commission, for specific services performed or for management, or by way of interest on moneys lent to the permanent establishment. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the . The method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles Articles: shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the an enterprise may also be taxed in the other State but only so much of them as is attributable directly or indirectly to that permanent establishment. The words "directly or indirectly" mean, for the purposes of this Article, that where a permanent establishment takes an active part in negotiating, concluding or fulfilling contracts entered not by the enterprise, then notwithstanding that other parts of the enterprise have also participated in those transactions, there shall be attributed to the permanent establishment that proportion of profits of the enterprise arising out of those contracts as the contribution of the permanent establishment to those transactions bears to that of the enterprise as a whole. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the profits of a permanent establishment, there shall be allowed as deductions deduction expenses which are incurred for the purposes of the business of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhereelsewhere in accordance with the provisions of and subject to the limitations of the tax law of that State. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; , the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Articlearticle. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only on so much of them thereof as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- ment, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State If the information available to the competent authority is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed determination of the tax liability of a person by such the exercise of a discretion or the making of an apportionment as may be customary; estimate by the method of apportionment adopted shallcompetent authority, however, be such provided that the result law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles contained in principle of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes purpose of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other Contracting State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where Where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently at arm’s length with the enterprise of which it is a permanent establishment. 3. In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses of the enterprise (other than expenses, which would not be deductible if the permanent establishment were a separate enterprise) which are incurred for the purposes of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the Contracting State in which the permanent establishment is situated or elsewhere. 4. Insofar In so far as it has been customary in a Contracting State according to its law, to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits income of the enterprise to its various parts, parts nothing in paragraph 2 (2) of this Article shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in of this Article. 5. No profits shall be attributed to a permanent establishment by reason of on the mere purchase by that permanent establishment of goods or of merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is a good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article. 8. Where profits are attributable to a permanent establishment situated in a Contracting State of an enterprise of the other Contracting State and those profits are remitted in whole or in part out of the first- mentioned State, then the profits so remitted shall not be subject to any greater charge to tax in the first- mentioned State then if they had not been so remitted. 9. Nothing in this Article shall affect any provisions of the law of either Contracting State regarding the taxation of: (a) any person who carries on a business of any form of insurance. Provided that if the law in force in either Contracting State at the date of signature of this Convention relating to t he taxation of any such person is varied (otherwise than in minor respects so as not to affect its general character), the Contracting Governments shall consult each other with a view to agreeing to such amendment of this sub-paragraph as may be necessary; (b) any income from the alienation of immovable property as defined in paragraph (2) of Article 7 which is situated in that Contracting State or from the alienation of shares in a company incorporated in that Contracting State whose assets consist wholly or mainly of such immovable property situated therein.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only on so much of them thereof as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- ment, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State If the information available to the competent authority is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed determination of the tax liability of a person by such the exercise of a discretion or the making of an apportionment as may be customary; estimate by the method of apportionment adopted shallcompetent authority, however, be such provided that the result law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles contained in of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere, but this does not include any expenses which under the law of that State would not be allowed to be deducted by an enterprise of that State. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained laid down in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that State 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only on so much of them thereof as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where Where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentall expenses, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 65. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 76. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State territory shall be taxable only in that State territory unless the enterprise carries on business in the other Contracting State territory through a permanent establishment situated therein. If the enterprise carries on business as afore- saidaforesaid, the profits of the enterprise may be taxed in the other State territory but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State territory carries on business in the other Contracting State territory through a permanent establish- ment establishment situated therein, there shall in each Contracting State territory be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishmentindependently. 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State territory in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State territory to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State territory from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. (1. ) The profits of an enterprise of a one of the Contracting State States shall be taxable only in that State Contracting 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 afore- saidaforesaid, tax may be imposed in that other Contracting State on the profits of the enterprise may be taxed in the other State but only on so much of them thereof as is attributable to that permanent establishment. (2. Subject to the provisions of paragraph 3, where ) Where an enterprise of a one of the Contracting State States carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently at arm's length with the enterprise of which it is a 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 establish- mentall expenses, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the Contracting State in which the permanent establishment is situated or elsewhere. (4. Insofar ) In so far as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 (2) of this article shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article.result (5. ) No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. (6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. ) Where profits include items of income any item which are is dealt with separately in other Articles another article of this Convention, then the provisions of those Articles that other article shall not be affected by the provisions of this Articlearticle.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated thereinin that other Contracting State. If the enterprise carries on or has carried on business as afore- saidin that manner, the profits of the enterprise may be taxed in the other Contracting State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the profits of a permanent establishment, there shall be allowed as deductions those deductible expenses which are incurred for the purposes of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the Contracting State in which the permanent establishment is situated or elsewhere. 4. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 5. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment appointment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income or gains which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other Contracting State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the Contracting State in which the permanent establishment is situated or elsewhere, but this does not include any expenses which under the law of that Contracting State would not be allowed to be deducted by an enterprise of that Contracting State. 4. Insofar In so far as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained laid down in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only on so much of them thereof as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- ment, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State If the information available to the competent authority is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed determination of the tax liability of a person by such the exercise of discretion or the making of an apportionment as may be customary; estimate by the method of apportionment adopted shallcompetent authority, however, be such provided that the result law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles contained in principle of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 33 of this Article, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. However, no such deduction shall be allowed in respect of amounts, if any, paid (otherwise than towards reimbursement of actual expenses) by the permanent establishment to the enterprise or any of its other offices, by way of royalties, fees or other similar payments in return for the use of patents or other rights, or by way of commission, for specific services performed or for management, or, except in case of a banking enterprise, by way of interest on money lent to the permanent establishment by the enterprise. 4. Insofar as it has been customary in a Contracting State to determine determine, according to its laws, the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 of this Article shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State Contracting State, but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 business of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment estoblishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the . The method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphsparagraphs 1 to 5, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated thereinin that other State. If the enterprise carries on business as afore- saidin that manner, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated thereinin that other State, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishmentestablishment or with other enterprises with which it deals. 3. In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses of the enterprise, being expenses which are incurred for the purposes of the permanent establish- ment, establishment (including executive and general administrative expenses so incurred) and which would be deductible if the permanent establishment were an independent entity which paid those expenses, whether incurred in the Contracting State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 65. For Nothing in this Article shall affect the purposes application of any law of a Contracting State relating to the determination of the preceding paragraphs, tax liability of a person in cases where the information available to the competent authority of that State is inadequate to determine the profits to be attributed to the a permanent establishment establishment, provided that that law shall be determined by applied, so far as the same method year by year unless there is good and sufficient reason information available to the contrarycompetent authority permits, consistently with the principles of this Article. 76. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article. 7. Nothing in this Article shall affect the operation of any law of a Contracting State relating to tax imposed on profits from insurance with nonresidents provided that if the relevant law in force in either Contracting State at the date of signature of this Agreement is varied (otherwise than in minor respects so as not to affect its general character) the Contracting States shall consult with each other with a view to agreeing to any amendment of this paragraph that may be appropriate.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 or has carried on business as afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishmentestablishment and with all other persons. 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the Contracting State in which the permanent establishment is situated or elsewhere. 4. Insofar In so far as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the . The method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only on so much of them thereof as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in on the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the profits of a permanent establishment, there shall be allowed as deductions deduction expenses which are incurred for the purposes of the permanent establish- ment, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were an independent enterprise, insofar, as they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State If the information available to the competent authority is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed determination of the tax liability of a person by such the exercise of a discretion or the making of an apportionment as may be customary; estimate by the method of apportionment adopted shallcompetent authority, however, be such provided that the result law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles contained in principle of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes purpose of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. (1. ) The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. (2. ) Subject to the provisions of paragraph (3), where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishmentestablishment or with other enterprises with which it deals. (3. ) In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses of the enterprise, being expenses which are incurred for the purposes of the permanent establish- ment, establishment (including executive and general administrative expenses so incurred) and which would be deductible if the permanent establishment were an independent entity which paid those expenses, whether incurred in the Contracting State in which the permanent establishment is situated or elsewhere. (4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. ) No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. (5) Nothing in this Article shall affect the application of any law of a Contracting State relating to the determination of the tax liability of a person in cases where the information available to the competent authority of that State is inadequate to determine the profits to be attributed to a permanent establishment, provided that that law shall be applied, so far as the information available to the competent authority permits, consistently with the principles of this Article. (6. ) Where profits include items of income which are dealt with separately in other Articles of this Agreement, then the provisions of those Articles shall not be affected by the provisions of this Article. (7) For the purposes of the preceding paragraphs, the profits profit to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where (8) Nothing in this Article shall affect the operation of any law of a Contracting State relating to tax imposed on profits include items from insurance with non-residents, provided that if the relevant law in force in either Contracting State at the date of income which are dealt with separately in other Articles signature of this Convention, then Agreement is varied (otherwise than in minor respects so as not to affect its general character) the provisions of those Articles Contracting States shall not be affected by the provisions consult with a view to agreeing to any amendment of this Articleparagraph that may be appropriate.

BUSINESS PROFITS. (1. ) The business profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. (2. ) Subject to the provisions of paragraph (3) of this Article, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- ment, establishment including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. (4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. ) No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. (5) For the purposes of the preceding paragraphsparagraphs of this Article, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. (6) Where profits include items of income or capital gains which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article. (7) In applying paragraphs (1) and (2) of this Article, income or profits attributable to a permanent establishment may, notwithstanding that the permanent establishment has ceased to exist, be taxed in the Contracting State in which it was situated. (8) Nothing in this Convention shall affect the taxation in Chile of a resident of the United Kingdom in respect of profits attributable to a permanent establishment situated in Chile, under both the first category tax and the additional tax. (9) Nothing in this Convention shall affect the application of the existing provisions of the Chilean legislation Decree Law 600 (Foreign Investment Statute) as they are in force at the time of signature of this Convention and as they may be amended from time to time without changing the general principle thereof.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentexpenses, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State If the information available to the competent authority is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed determination of the tax liability of a person by such the exercise of a discretion or the making of an apportionment as may be customary; estimate by the method of apportionment adopted shallcompetent authority, however, be such provided that the result law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles contained in principle of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes purpose of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. Such deductions shall be determined in accordance with domestic law. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State Party shall be taxable only in that State Party unless the enterprise carries on business in the other Contracting State Party through a permanent establishment situated therein. If the enterprise carries on business as afore- saidaforesaid, the profits of the enterprise may be taxed in the other State Party, but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 33 of this Article, where an enterprise of a Contracting State Party carries on business in the other Contracting State Party through a permanent establish- ment establishment situated therein, there shall in each Contracting State Party be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State Party in which the permanent establishment is situated or elsewhere, which are allowed under the provisions of the domestic law of the Contracting Party in which the permanent establishment is situated. 4. Insofar as it has been customary in a Contracting State Party to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 of this Article shall preclude that Contracting State Party from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is directly or indirectly attributable to that permanent establishmentestablishment . 2. Subject to the provisions of paragraph 3, 3 of this Article where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- ment, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State If the information available to the competent authority is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed determination of the tax liability of a person by such the exercise of a discretion or the making of an apportionment as may be customary; estimate by the method of apportionment adopted shallcompetent authority, however, be such provided that the result law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles contained in of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrarycontrary . 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where Where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the determination of the profits of a permanent establishment, establishment there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establish- mententerprise, including executive and general administrative expenses so incurredexpenses, whether in which are deductible according to the law of the State in which the permanent establishment is situated whether incurred in that State or elsewhere. 4. Insofar as it has been customary in If the information available to the competent authority of a Contracting State is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment enterprise, the competent authority may apply to that enterprise for that purpose the provisions of the total profits taxation law of the enterprise to its various partsthat State, nothing in paragraph 2 shall preclude provided that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles contained in of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article. 7. Notwithstanding the preceding provisions of this Article, profits of an enterprise of a Contracting State from carrying on a business of any form of insurance other than life insurance may be taxed in the other Contracting State in accordance with the law of that other State relating specifically to the taxation of any person who carries on such a business, provided that if the law in force in either Contracting State at the date of signature of this Convention relating to the taxation of such a person is varied (otherwise than in minor respects so as not to affect its general character), the Contracting States shall consult with each other with a view to agreeing to such amendment of this paragraph as may be necessary.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 33 of this Article, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining of the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine determine, according to its laws, the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 of this Article shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other Contracting State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 33 of this Article, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the Contracting State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 of this Article shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 6. Where a resident of a Contracting State beneficially owns (whether as a direct beneficiary of a trust or through one or more interposed trusts) a share of the profits of a business of an enterprise carried on in the other Contracting State by the trustee of a trust other than a trust which is treated as a company for tax purposes; and in relation to that enterprise, that trustee has or would have, if it were a resident of the first-mentioned Contracting State, a permanent establishment in the other Contracting State, then the business of the enterprise carried on by the trustee through such permanent establishment shall be deemed to be a business carried on in the other Contracting State by that resident through a permanent establishment situated in that other Contracting State and the resident’s share of profits may be taxed in the other Contracting State but only so much of them as is attributable to that permanent establishment. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article. 8. Nothing in this Article shall affect any provisions of the laws of either Contracting State at any time in force as they affect the taxation of any income from any form of insurance.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 a permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere, within the framework determined by the domestic legislation of that State. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is are attributable to that permanent establishment or are derived within such other Contracting State from sales of goods or merchandise of the same or similar kind as those sold, or from other business transactions of the same or similar kind as those effected through the permanent establishment. The competent authorities of the Contracting States shall consult each other on the similarity of goods sold or business transactions. 2. Subject to the provisions of paragraph 3, 3 where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the determination of the business profits of a permanent establishment, there shall be allowed as deductions deduction expenses which are incurred for the purposes of the business of the permanent establish- ment, establishment including executive and general administrative expenses so incurredexpenses, whether incurred in the Contracting State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained embodied in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The Income or profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the income or profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the income or profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the business of the permanent establish- ment, establishment including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in If the information available to the taxation authority of a Contracting State is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed by such an apportionment as may be customary; determination of the method tax liability of apportionment adopted shall, however, be such a person provided that the result law shall be in accordance applied, so far as the information available to the taxation authority permits, consistently with the principles contained in of this Article. 5. No income or profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the income or profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where income or profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a one of the Contracting State States shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a one of the Contracting State States carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishmentestablishment or with other enterprises with which it deals. 3. In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses of the enterprise, being expenses which are incurred for the purposes of the permanent establish- ment, establishment (including executive and general administrative expenses so incurred) and which would be deductible if the permanent establishment were an independent entity which paid those expenses, whether incurred in the Contracting State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 65. For Nothing in this Article shall affect the purposes application of any law of a Contracting State relating to the determination of the preceding paragraphs, tax liability of a person in cases where the information available to the competent authority of that State is inadequate to determine the profits to be attributed to the a permanent establishment establishment, provided that that law shall be determined by applied, so far as the same method year by year unless there is good and sufficient reason information available to the contrarycompetent authority permits, consistently with the principles of this Article. 76. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article. 7. Nothing in this Article shall affect the operation of any law of a Contracting State relating to tax imposed on profits from insurance with nonresidents provided that if the relevant law in force in either Contracting State at the date of signature of this Agreement is varied (otherwise than in minor respects so as not to affect its general character) the Contracting States shall consult with each other with a view to agreeing to any amendment of this paragraph that may be appropriate.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other Contracting State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 business of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the Contracting State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of a certain percentage of the gross receipt of the enterprise or of the permanent establishment or on the basis of an apportionment of the 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 such an apportionment a method as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 33 of this Article, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 business of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in If the information available to the taxation authority of a Contracting State is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed by such an apportionment as may be customary; determination of the method tax liability of apportionment adopted shall, however, be such a person provided that the result law shall be in accordance applied, so far as the information available to the taxation authority permits, consistently with the principles contained in of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other Contracting State but only so much of them as is attributable to that permanent establishment.. 812 Government Notices 1994 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 business of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the . The method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphsparagraphs 1 to 5, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the the. contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the profits of a permanent establishmentestablishment in a Contracting State, there shall be allowed as deductions expenses (other than expenses which would not be deductible if that permanent establishment were a separate enterprise of that Contracting State) which are incurred for the purposes of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State Party shall be taxable only in that State Contracting Party unless the enterprise carries on business in the other Contracting State Party through a permanent establishment situated therein. If the enterprise carries on business as afore- saidaforesaid, the profits of the enterprise may be taxed in the other State Contracting Party, but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State Party carries on business in the other Contracting State Party through a permanent establish- ment establishment situated therein, there shall in each Contracting State Party be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishmentestablishment or with other enterprises with which it deals. 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State Contracting Party in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State Party to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State Party from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. If the information available to the taxation authority of a Contracting Party is inadequate to determine the profits to be attributed to the permanent establishment of an enterprise, nothing in this Article shall affect the application of any law of that Contracting Party relating to the determination of the tax liability of a person provided that that law shall be applied in accordance with the principles of this Article, so far as the information available to the taxation authority permits. 7. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 78. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 or has carried on business as afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment situated therein, there shall in each Contracting State be attributed to that perma- nent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar conditions and dealing wholly independently with the enterprise of which it is a 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 establish- ment, establishment including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 33 of this Article, where an enterprise of a Contracting State carries on or has carried on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the profits of a permanent establishment, there shall be allowed as deductions those deductible expenses which are incurred for the purposes of the business of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 of this Article shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the . The method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphsparagraphs of this Article, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions deduction expenses which are incurred for the purposes of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere, which are allowed under the provisions of the domestic law of the Contracting State in which the permanent establishment is situated. 4. Insofar as it has been customary in a Contracting State If the information available to the competent authority is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed determination of the tax liability of a person by such the exercise or a discretion or the making of an apportionment as may be customary; estimate by the method of apportionment adopted shallcompetent authority, however, be such provided that the result law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles contained in of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.contrary.‌ 7. Where profits include items of income income, which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated thereinterein. If the enterprise carries on business as afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is it directly or indirectly attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, 3 of this Article where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated thereintherin, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it in might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes purpose of the business of the permanent establish- ment, establishment including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of a certain reasonable percentage of the gross receipt of the enterprise or on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that such Contracting State from determining the profits to be taxed by any of such an apportionment as may be customarymethod ; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained principle laid down in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 6. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 7. Where profits include items of income which are dealt with separately in other Articles Article of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article. 8. For the purpose of paragraph 1, the term “ directly or indirectly attributable to the permanent establishment” include profits arising from transactions in which the permanent establishment has been involved and such profits shall be regarded as attributable to the permanent establishment to the extent appropriate to the part played by the permanent establishment in those transactions, even if those transactions are made or placed directly with the overseas head office of the enterprise rather than with the permanent establishment.

BUSINESS PROFITS. 1. ) The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated thereinsitua- xxx xxxxxxx. If the enterprise carries on business bu- siness as afore- saidaforesaid, the profits of the enterprise enter- prise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. ) Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment es- tablishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishmentindependently. 3. ) In determining the profits of a permanent perma- nent establishment, there shall be allowed as deductions expenses which are necessa- ry and incurred for the purposes of the permanent establish- mentestablishment, including executive execu- tive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. Only that part of the expenses that is attributable to the permanent esta- blishment shall be allowed as a deduction. 4. ) Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment establish- ment on the basis of an apportionment of the total profits of the enterprise to its various va- rious parts, nothing in paragraph 2 shall preclude that Contracting State from determining de- termining the profits to be taxed by such an apportionment as may be customarycustomary ; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. ) No profits shall be attributed to a permanent per- manent establishment by reason of the mere me- re purchase by that permanent establishment establish- ment of goods or merchandise for the enterpriseen- terprise. 6. ) For the purposes of the preceding paragraphspara- graphs, the profits to be attributed to the permanent establishment shall be determined determi- xxx by the same method year by year unless un- less there is good and sufficient reason to the contrary. 7. ) Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions provi- sions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a one of the Contracting State States shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State State, but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a one of the Contracting State States carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishmentestablishment or with other enterprises with which it deals. 3. In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses of the enterprise, being expenses which are incurred for the purposes of the permanent establish- ment, establishment (including executive and general administrative expenses so incurred) and which would be deductible if the permanent establishment were an independent entity which paid those expenses, whether incurred in the Contracting State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 5. Nothing in this Article shall affect the operation of any law of a Contracting State relating to taxation of profits from insurance with non-residents provided that if the relevant law in force in either State at the date of signature of this Convention is varied (otherwise than in minor respects so as not to affect its general character) the Contracting States shall consult with each other with a view to agreeing to any amendment of this paragraph that may be appropriate. 6. For the purposes of the preceding paragraphsthis Article, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits of an enterprise do not include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by Convention and the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph (3) of this article, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. Where the correct amount of profits attributable to a permanent establishment cannot be readily determined or the determination thereof presents exceptional difficulties, the profits attributable to the permanent establishment may be estimated on a reasonable basis. 3. In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the business of the permanent establish- ment, establishment including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 65. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 76. Where profits include items of income which are dealt with separately in other Articles articles of this Convention, then the provisions of those Articles articles shall not be affected by the provisions of this Articlearticle.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to to: a. that permanent establishment; or b. sales in that other State of goods or merchandise of the same or similar kind as those sold through that permanent establishment; or c. other business activities carried on in that other State of the same or similar kind as those effected through that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the profits of a permanent establishment, there shall be allowed as deductions deduction expenses which are incurred for the purposes of the business of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhereelsewhere in accordance with the provisions of and subject to the limitations of the tax laws of that State. 4. Insofar In so far as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; , the method of apportionment adopted shall, shall however, be such that the result shall be in accordance with the principles contained in this Articlearticle. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles articles of this ConventionAgreement, then the provisions of those Articles articles shall not be affected by the provisions of this Articlearticle.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated thereinin that other State. If the enterprise carries on business as afore- saidin that manner, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 33 of this Article, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated thereinin that other State, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishmentestablishment or with other enterprises. 3. In determining the profits of a permanent establishment, there shall be allowed as deductions expenses of the enterprise, being expenses which are incurred for the purposes of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the Contracting State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary Nothing in this Article shall affect the application of any law of a Contracting State relating to the determination of the tax liability of a person in cases where the information available to the competent authority of that State is inadequate to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude establishment. In such cases that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result law shall be in accordance applied, having regard to the information that is available, consistently with the principles contained in of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income or gains which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article. 7. Nothing in this Article shall affect the operation of any law of a Contracting State relating to tax imposed on profits from insurance with non-residents provided that if the relevant law in force in either Contracting State at the date of signature of this Convention is varied (otherwise than in minor respects so as not to affect its general character) the Contracting States shall consult with each other with a view to agreeing to any amendment of this paragraph that may be appropriate. ARTICLE 8

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only on so much of them thereof as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. 3. In determining the profits of a permanent establishment, there shall be he allowed as deductions expenses which are incurred for the purposes of the permanent establish- ment, including executive and general administrative expenses so incurredexpenses, which would be deductible if the permanent establishment were an independent enterprise, insofar as they are reasonably allocable to the permanent establishment, whether incurred in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State If the information available to the competent authority is inadequate to determine the profits to be attributed to a the permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various partsenterprise, nothing in paragraph 2 this Article shall preclude affect the application of any law of that Contracting State from determining relating to the profits to be taxed determination of the tax liability of a person by such the exercise of a discretion or the making of an apportionment as may be customary; estimate by the method of apportionment adopted shallcompetent authority, however, be such provided that the result law shall be applied, so far as the information available to the competent authority permits, in accordance with the principles contained in principle of this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes purpose of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is a good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State State, but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a 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 business of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. This provision shall apply subject to limitations under the domestic law. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the . The method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. (1. ) The profits of an enterprise of a one of the Contracting State States shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State State, but only so much of them as is attributable to that permanent establishment. (2. ) Subject to the provisions of paragraph (3), where an enterprise of a one of the Contracting State States carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishmentestablishment or with other enterprises with which it deals. (3. ) In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses of the enterprise, being expenses which are incurred for the purposes of the permanent establish- ment, establishment (including executive and general administrative expenses so incurred) and which would be deductible if the permanent establishment were an independent entity which paid those expenses, whether incurred in the Contracting State in which the permanent establishment is situated or elsewhere. (4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. ) No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. (5) Nothing in this Article shall affect the operation of any law of a Contracting State relating to taxation of profits from insurance with non-residents provided that if the relevant law in force in either State at the date of signature of this Convention is varied (otherwise than in minor respects so as not to affect its general character) the Contracting States shall consult with each other with a view to agreeing to any amendment of this paragraph that may be appropriate. (6. ) For the purposes of the preceding paragraphsthis Article, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits of an enterprise do not include items of income which are dealt with separately in other Articles of this Convention, then Convention and the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The business profits of an enterprise a resident of a Contracting State shall be taxable only in that State unless the enterprise resident carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise resident carries on or has carried on business as afore- saidaforesaid, the business profits of the enterprise resident may be taxed in the other State but only so much of them as is attributable to to: (a) that permanent establishment; (b) sales in that other State of goods or merchandise of the same kind as those sold through that permanent establishment; or (c) other business activities carried on in that other State of the same kind as those effected through that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise a resident of a Contracting State carries on or has carried on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the business profits which it might be expected to make if it were a distinct and separate enterprise person engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishmentresident and with all other persons. 3. In determining the determination of the business profits of a permanent establishment, there shall be allowed as deductions those deductible expenses which are incurred for the purposes of the permanent establish- mentestablishment, including executive and general administrative expenses so incurredexpenses, whether incurred in the State in which the permanent establishment is situated or elsewhere. The permanent establishment shall not be allowed a deduction (otherwise than as a reimbursement of actual expenses) for amounts paid to its head office or any of the other offices of the company by way of royalties, fees or other similar payment in return for the use of patents or other rights, or by way of commission, for specific services performed or for management, or by way of interest on moneys lent to the permanent establishment. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No business profits shall be attributed to a permanent establishment of a person by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterpriseperson. 5. Where the information available to or readily obtainable by the competent authority of a Contracting State is not adequate to determine the business profits or expenses of a permanent establishment, profits may be calculated in accordance with the tax laws of that State. For purposes of this paragraph, information will be considered to be readily obtainable if the taxpayer provides the information to the requesting competent authority within 91 days of a written request by the competent authority for such information. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where business profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article. 7. For the purposes of the preceding paragraphs, the business profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.

BUSINESS PROFITS. (1. ) The profits of an enterprise of a one of the Contracting State States shall be taxable only in that State unless the enterprise carries on business in the other Contracting State state through a permanent establishment situated therein. If the enterprise carries on business as afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. (2. ) Subject to the provisions of paragraph (3), where an enterprise of a one of the Contracting State States carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishmentestablishment or with other enterprises with which it deals. (3. ) In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses of the enterprise, being expenses which are incurred for the purposes of the permanent establish- ment, establishment (including executive and general administrative expenses so incurred) and which would be deductible if the permanent establishment were an independent entity which paid those expenses, whether incurred in the Contracting State in which the permanent establishment is situated or elsewhere. (4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. ) No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. (5) Nothing in this Article shall affect the application of any law of a Contracting State relating to the determination of the tax liability of a person, including the determination of such liability by the exercise of a discretion or the making of an estimate by the competent authority of that State in cases in which, from the information available to the competent authority of that State, it is not possible or not practicable to ascertain the profits to be attributed to a permanent establishment, provided that that law shall be applied, so far as the information available to the competent authority permits, consistently with the principles of this Article. (6. ) For the purposes of the preceding paragraphsparagraphs of this Article, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. (7. ) Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article. (8) Nothing in this Article shall affect the operation of any law of a Contracting State relating to taxation of profits from insurance with non-residents provided that if the relevant law in force in either Contracting State at the date of signature of this Agreement is varied (otherwise than in minor respects so as not to affect its general character) the Contracting States shall consult with each other with a view to agreeing to any amendment of this paragraph that may be appropriate.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 33 of this Article, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.or 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 establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere, and which are reasonably connected with profits attributable to the permanent establishment. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 of this Article shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes of the preceding paragraphsparagraphs of this Article, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Nothing in this Article shall effect any provisions of the law of either Contracting State at any time in force regarding the taxation of any income or profits from the business of any form of insurance. 8. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State one of the States shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State one of the States carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. In any case where the correct amount of profits attributable to a permanent establishment is incapable of determination or the determination thereof presents exceptional difficulties, the profits attributable to the permanent establishment may be estimated on the basis of an apportionment of the total profits of the enterprise to its various parts, provided, however, that the result shall be in accordance with the principles contained in this Article. 3. (a) In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establish- mentestablishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained provisions of and subject to the limitations of the taxation laws of that State. Provided that where the law of the State in which the permanent establishment is situated imposes a restriction on the amount of the executive and general administrative expenses which may be allowed, and that restriction is relaxed or overridden by any Convention between that State and a third State which enters into force after the date of entry into force of this ArticleConvention, the competent authority of that State shall notify the competent authority of the other State of the terms of the corresponding paragraph in the Convention with that third State immediately after the entry into force of that Convention and, if the competent authority of the other State so requests, the provisions of this sub-paragraph shall be amended by protocol to reflect such terms. 5(b) However, no such deduction shall be allowed in respect of amounts, if any, paid (otherwise than towards reimbursement of actual expenses) by the permanent establishment to the head office of the enterprise or any of its other offices, by way of royalties, fees or other similar payments in return for the use of patents or other rights, or by way of commission for specific services performed or for management, or, except in the case of a banking enterprise, by way of interest on moneys lent to the permanent establishment. 4. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 65. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 76. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

BUSINESS PROFITS. (1. ) The profits of an enterprise of a one of the Contracting State States shall be 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 afore- saidaforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. (2. ) Subject to the provisions of paragraph (3) of this Article, where an enterprise of a one of the Contracting State States carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishmentestablishment or with other enterprises with which it deals. (3. ) In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses of the enterprise, being expenses which are incurred for the purposes of the permanent establish- ment, establishment (including executive and general administrative expenses so incurred) and which would be deductible if the permanent establishment were an independent entity which paid those expenses, whether incurred in the Contracting State in which the permanent establishment is situated or elsewhere. (4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the 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 such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. 5. ) No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For (5) If the purposes information available to the competent authority of the preceding paragraphs, a Contracting State is inadequate to determine the profits to be attributed to the permanent establishment of an enterprise, nothing in this Article shall affect the application of any law of that State relating to the determination of the tax liability of a person provided that that law shall be determined by applied, so far as the same method year by year unless there is good and sufficient reason information available to the contrarycompetent authority permits, in accordance with the principles of this Article. 7. (6) Where profits include items of income which are dealt with separately in other Articles of this ConventionAgreement, then the provisions of those Articles shall not be affected by the provisions of this Article. (7) Nothing in this Article shall apply to either Contracting State to prevent the operation in the Contracting State of any provision of its law relating specifically to the taxation of any person who carries on a business of any form of insurance.

BUSINESS PROFITS. 1. The profits of an enterprise of a Contracting State shall be 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 afore- saidaforesaid, then so much of the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishmentestablishment shall be taxable only in that other Contracting State. 2. Subject to the provisions of paragraph 3, where Where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establish- ment establishment situated therein, there shall in each Contracting State be attributed to that perma- nent permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or simi- lar similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. In any case, where the correct amount of profits attributable to a permanent establishment is incapable of determination or the ascertainment thereof presents exceptional difficulties, the profits attributable to the permanent establishment may be computed on a reasonable basis. 3. In determining the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes purpose of the permanent establish- ment, establishment including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere, but this does not include any expenses which, under the law of that State, would not be allowed to be deducted by an enterprise of that State. 4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 (2) shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained laid down in this Article. 5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. 6. For the purposes purpose of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.