43 | II Série A - Número: 053S1 | 23 de Dezembro de 2014

a
3 — The provisions ofparagraph
1 s1a1i apply to nome
derived from the direct use, letting, or use in
any other form
of immovable property.
4 — The provisions of paragraphs 1 and 3 shall
also
apply to the income from immovable
property of an.en
terprise and to income from immovable
property used for
the performance of independent personal
services.
5 — The foregoing provisions
shall also apply to income
from movable properly, or.incorne .derived
from srvices
connected with the use or the
right to use the irnmovable
property,. either of which, under the
taxation law of the
Contracting Stat in which the propertyis
situated, is as
similated to incõrne from immovable
property:
Article 7
Business profits
1 — The profits of an
enterprise of a .Contracting State
shall be taxable only ia that State unless
the enierprise
carnes on business in the õther Contracting
State through a
permanent establishment situated therein.
Ifthe enterprise
carnes on business as aforesaid, the profits
ofthe enterprise
may be taxed in the other State but only
so much ofthem
as is attributable to that
permanent establishment.
2 — Subject to the provisions of
paragraph.3, where
an enterprise of a Contracting State
carnes on business in
the other Contracting State through a
permanent estabiish
ment situated therein, there shall in each
Contracting State
be attributed to that permanent establishment
the profits
which it rnight be expected to
make if it were a distinct
and separate enterprise engaged in
the sarne or similar
activities under the sarne ar similar conditions
and deaiing
whollyindependently with the
enterprise ofwhicl it is a
permanent estahlishrnent.
3 In determining the
profits of a permanent esta
blishment, there shall be allowed as
deductions expenses
which are incurred for the purposes
ofthe permanent esta
blishment, including executive and
general administrative
expenses so incurred, whether in
the State in which the
perrnanent estahlishment is situated
or eisewhere.
4 — insofar as it ha beéh
üstõmary in a Contracting
State Lo determine the profits to be
attributed to a perma
nent establishrnent on the basis.ofanapportionmcr&t
ofthe
total profits of the enterprise to its
various parts nothing
in paragraph 2 shall preclude that Contracting
State from
determining the profits to betaxed
by such an apportion
ment as may be customary; the
method of apporLionment
adopted shall, however, be such that
the result shall be in
accordance with the principies contained
in this artiele.
5 — No profits shall he.attributed
to a permanent,es
tablishrnent by reason of the mere
purchase by that per
manent establishrnent of goods
or merchandise for the
enterprise..
6 -—For the purposes ofthe
preceding paragraphs, the
profits to be attributed to
the permanent establishmcnt shall
be determined by the sarne rnethod
year by year.uniess
there is good and sufficient reason.
to the contrary.
7 — Where profits inciude items
of income which are
deait with separately in other
articies ofthis Conyention,
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