Diplomatic and consular activities

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..... e Rule 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 exempt .....

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..... h 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 item .....

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..... Notwithstanding any provisions of the Convention, a benefit under the Convention shall not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established th .....

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