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CHAPTER I - Income Tax
CHAPTER II - Registration Fees and Stamp Duties
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.

ARTICLE 10

[Business Profits]

(1) Income from industrial, mining, business or financial enterprises shall be taxable only in the State in whose territory a permanent establishment is located.

(2) When a company has permanent establishments in both Contracting States, each State may tax only the income arising from the activity of the permanent establishments within its territory.

(3) The taxable income can-not exceed the amount of industrial, mining, commercial or financial profits made by the permanent establishment, including where applicable, the benefits or advantages derived indirectly from that establishment or which would have been allocated or awarded to third parties either by increasing or decreasing prices for the purchase or sale, or by any other means. A share of general expenses from the head office shall be attributed to the results of various permanent establishments in proportion to the result realized in each of them.

(4) Where taxpayers whose business spans the territories of the two Contracting States do not keep proper accounts showing clearly and exactly the profits attributable to permanent establishments located in either State, the profit to be respectively taxed by these States can be determined by apportioning the overall earnings in proportion to the turnover realized in each  of them.

(5) In the case where establishments located in either Contracting State do not realize a turnover and where the activities in each State are not comparable, the competent authorities of the two States shall consult each other to determine the conditions of application of paragraphs (3) and (4) above.