3. pants

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.