Artikel VIII

It is understood that interest, wages and salaries paid by an enterprise carried on by a company that is a resident of a Contracting State, the capital of which is wholly or partly owned by a resident of the other Contracting State, shall be equally deductible in computing the taxable profits of that enterprise as in the case that such interest, wages and salaries were paid by a company that is a resident of the first-mentioned State, the capital of which is wholly or partly owned by a resident of that first-mentioned State. Accordingly, interest, wages and salaries borne by a permanent establishment of an enterprise carried on by a resident of a Contracting State in the other Contracting State, or borne by a fixed base of a resident of a Contracting State in the other Contracting State, shall be equally deductible in computing the taxable profits of such permanent establishment or the taxable income of such fixed base as in the case that such interest, wages and salaries were paid by an enterprise which is a resident of the first-mentioned State.