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4. The provisions of paragraphs 1 and 3 shall also apply to the income from immovable property of an

enterprise 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 property, or income derived from

services connected with the use or the right to use the immovable property, either of which, under the taxation

law of the Contracting State in which the property is situated, is assimilated to income from immovable

property.

ARTICLE 7

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 aforesaid, 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 establishment situated therein, there shall in

each Contracting State be attributed to that 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

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 establishment, 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

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. Likewise, no account shall be taken, in the determination of the profits of a

permanent establishment, for amounts charged (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 banking enterprise

by way of interest on moneys lent to the head office of the enterprise or any of its other offices.

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 in order to continue production or processing by 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

Agreement, then the provisions of those Articles shall not be affected by the provisions of this Article.