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3. In determining the tax of one of the contracting States, no account shall be taken of the mere/purchase of merchandise therein by an enterprise of the other contracting State for that enterprise.

4. Income derived from the sale of goods (excluding the kind of income mentioned in the following paragraph) shall be treated, for the purposes of application of the provisions of paragraph 1 above, as derived from the country in which such goods are sold.

5. Income derived from the sale by an enterprise in one of the contracting States of goods manufactured in the other contracting State in whole or in part by that enterprise shall be treated, for the purposes of application of the provisions of paragraph 1 above, as derived in part from the country in which the goods are manufactured and in part from the country in which the goods are sold.

6. The competent authorities of both contracting States may, consistent with the provisons of the present Convention, arrange details for the apportionment of industrial or commercial profits.

Where:

(a) an enterprise of one of the contracting States participates directly or indirectly in the managerial or financial control of an enterprise of the other contracting State, or

(b) the same individuals or corporations participate directly or indirectly in the managerial or financial control of an enterprise of one of the contracting States and an enterprise of the other contracting State,

and in either case, conditions are made or imposed between the two enterprises, in their commercial or financial relations, which differ from those which would be made between independent enterprises, then any profits which would but for those conditions have accrued to one of the enterprises but by reason of those conditions have not so accrued may be included in the profits of that enterprise and taxed accordingly.

Notwithstanding the provisions of Articles III and IV, profits which an enterprise of one of the contracting States derives from the operation of ships or aircraft registered

(a) in that contracting State or in the other contracting State, or

(b) in any third country which exempts from its tax profits derived from the operation of ships or aircraft registered in that other contracting State shall be exempt from the tax of that other contracting State.