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 is might be expected to  make if it where 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. 

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, 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 Agreement, then the provisions of those Articles shall not be  affected by the provisions of this Article.