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. 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 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 a 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 for the enterprise.  

6. For the purposes of the preceding paragraphs of this Article, 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 Convention, then the provisions of those Articles shall not be affected by the  provisions of this Article.  

8. The provisions of this Article shall apply also to profits derived by any partner from  his participation in a partnership and in any other body of persons which is subjected to the  same taxation treatment.