9. Article

In applying paragraphs 1 and 2 of this Article, paragraph 4 of Article 10 (Dividends), paragraph 5 of Article 11 (Interest), paragraph 4 of Article 12 (Royalties), paragraph 3 of Article 13 (Capital Gains), Article 14 (Independent Personal Services) and paragraph 2 of Article 22 (Other Income), income or gain may be attributable to a permanent establishment or fixed base even if the income or gain is deferred until after such permanent establishment or fixed base has ceased to exist. ARTICLE 8 Shipping and Air Transport