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(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 attri- butable to that permanent establishment.
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(2) Subject to the provisions of paragraph 3, where an enter- prise of a Contracting State carries on business in the other Contracting State through a permanent establishment situ- ated therein, there shall in each Contracting State be attribut- ed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enter- prise 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.
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(3) In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are in- curred for the purposes of the permanent establishment, in- cluding executive and general administrative expenses So in- curred, whether in the State in which the permanent establish- ment is situated or elsewhere.
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(4) Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent estab- lishment 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 cus- tomary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the prin- ciples contained in this Article.
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(5) No profits shall be attributed to a permanent establish- _ ment by reason of the mere purchase by that permanent estab- lishment of goods or merchandise for the enterprise.
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(6) For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be deter- mined by the same method year by year unless there is good and sufficient reason to the contrary.
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(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 provi- sions of this Article.