Article 7 - Business Profits

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....graph 2 may be taxed in that other State. [ Para 1 of Article 7 ] Attribution of Profit and Elimination of Double taxation * For the purposes of this Article and Article [23A] [23B], the profits that are attributable in each Contracting State to the PE referred to in paragraph 1 are the profits it might be expected to make, in particular in its dealings with other parts of the enterprise, if it were a separate and independent enterprise engaged in the same or similar activities under the same or similar conditions, taking into account the functions performed, assets used and risks assumed by the enterprise through the PE and through the other parts of the enterprise. [ Para 2 of Article 7 ] * Where, a Contracting State adjusts the prof....

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.... sales in that other State of goods or merchandise of the same or similar kind as those sold through that permanent establishment; or * (c) other business activities carried on in that other State of the same or similar kind as those effected through that permanent establishment. [ Para 1 of Article 7 ] Determination of Business Profit and allowed deduction of expenses * Determination of business profit - 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 t....