(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 State but only so much of them as is attributable to
that permanent establishment.
(2) 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 permanent establishment, including an
allocation of executive and general administrative expenses
incurred for the purposes of the enterprise as a whole, whether 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) 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.
