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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Business Profits

(1) The profits of an enterprise of a Contracting State are taxable only in that Contracting State, unless the enterprise does not carry on its activities in the other Contracting State by a permanent establishment, which is located there. If the enterprise carries on its activities in such a way, the profits of the enterprise are taxable in the other State, but only insofar as they are attributable to that permanent establishment.

(2) When an enterprise of a Contracting State carries on its activities in the other Contracting State through a permanent establishment located there, 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) To determine the profits of a permanent establishment, deduction to the expenditure occurred for this permanent establishment is allowed, including executive and general administrative expenses, in the State where this permanent establishment is located, 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) When the profit includes items of income dealt separately in other Articles of this Convention, the provisions of such Articles shall not be affected by the provisions of this Article.