3. Article
With reference to Article 7
a) In the Contracting State in which the permanent
establishment is situated, no profits shall be attributed to a
building site, a construction, assembly or installation project
except those which are the result of such activities
themselves. Profits derived from the supply of goods connected
with, or independent of, such activities and effected by the
principal permanent establishment or any other permanent
establishment of the enterprise or by a third party shall not
be attributed to the building site, a construction, assembly or
installation project.
b) Income derived from design, planning, engineering or
research or from technical services which a resident of a
Contracting State performs in that Contracting State and which
are connected with a permanent establishment referred to in
sub-paragraph a) in the other Contracting State shall not be
attributed to that permanent establishment.
- a)) In the Contracting State in which the permanent
- b)) Income derived from design, planning, engineering or