Business profits

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..... enterprise may be taxed in the other Contracting State but only so much of them as is attributable to that permanent establishment. 2. If an enterprise of a Contracting State, which has a permanent establishment in the other Contracting State, sells goods or merchandise of the same or similar kind as those sold by the permanent establishment or renders services of the same or similar kind as tho .....

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..... attributable to a permanent establishment is incapable of determination or the ascertainment thereof presents exceptional difficulties, the profits attributable to the permanent establishment may be estimated on a reasonable basis. 4. In so far 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 .....

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..... ed to be deducted by an enterprise of that State. 6. 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 purpose of export to the enterprise of which it is the permanent establishment. 7. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment s .....

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