Diplomatic and consular activities

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....le for Permanent Establishments Situated in Third Jurisdictions 1. Where: (a) an enterprise of a Contracting State derives income from the other Contracting State and the first-mentioned Contracting State treats such income as attributable to a permanent establishment of the enterprise situated in a third jurisdiction; and (b) the profits attributable to that permanent establishment are exemp....

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....ough the permanent establishment (other than the business of making, managing or simply holding investments for the enterprise's own account, unless these activities are banking, insurance or securities activities carried on by a bank, insurance enterprise or registered securities dealer, respectively). 3. If benefits under the Convention are denied pursuant to paragraph 1 with respect to an ....