Commercial and Industrial Profits
(1) Commercial and industrial profits achieved by a project of one of the contracting states are subject to taxes applicable in the state of project.
(2) If the project which is located in one of the contracting states practices a commercial or industrial activity in the other state through its permanent installation, then profits of the project accrued from activities of the permanent installation are subject to taxes of the state in which permanent installation of the project is located. And its profits are determined as if they are profits of an independent project which practices the same activity or a similar activity under the same conditions or under similar conditions and it is treated as completely independent from the project which is considered as a permanent installation therefor.
(3) Upon determination of profits of the permanent installation, the expenses pertinent to the permanent installation are deducted including the executive expenses and the general administrative expenses which are spent either in the state in which the permanent installation exists or in any other state.
(4) If it is customary in one of the contracting states to determine the profits pertinent to a permanent installation on the basis of a pro rata dividing of the total profits of the project over its different parts or in accordance with any other basis, then the provisions of paragraph (2) do not prevent such contracting state from determining the profits that are subject to the customary pro rata taxes. However, the pro rata pattern must lead to a result which conforms to the principles illustrated in this article.
(5) For the purposes of the previous paragraphs, profits that are pertinent to the permanent installation are determined by the same manner year after year in the absence of a proper and sufficient reason to the contrary.
(6) If profits include elements of income that are separately covered by other articles in the instant treaty, then the provisions of this article do not prejudice the provisions of the said articles.