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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 attributable 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 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.
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(3) In determining the profits of a permanent establishment, there shall be allowed as deductions all expenses, including executive and general administrative expenses, which would be deductible if the permanent establishment were an independent enterprise, whether incurred in the Contracting State in which the permanent establishment 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 establish- ment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall pre- clude 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.
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(5) No profits shall be attributed to a permanent establish- ment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise.
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(6) For the purposes of the preceding paragraphs of this Article, the profits to be attributed to the permanent establish- ment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.
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(7) This Article shall also apply to income of a resident of a Contracting State who carries on business in the other Con- tracting State as a partner of a partnership. It shall further apply to remuneration received by a partner from the partnership for activities in the service of the partnership and for the granting of loans or the provisions of assets to the partnership, where such remuneration is attributable under the tax law of the Contracting State in which the permanent establishment is situated to the income derived by a partner from that permanent establish- ment.
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(8) Where profits include items of income which are dealt with separately in other Articles of this Agreement, then the pro- visions of those Articles shall not be affected by the provisions of this Article.