2. For the purposes of this Article, profits, income or profits of a Party established in one Party that may be taxed in the other Party under this Agreement shall be deemed to be derived from sources in that other Contracting Party. 5. If a company established in one Contracting Party generates profits or income of the other Contracting Party, the other Contracting Party may not levy tax on dividends paid by the company unless such dividends are paid to a person established in that other Party or to the holding for which the dividends are paid; is effectively connected to an establishment located in that other part; the company`s unused earnings are not subject to tax on the company`s uninservient profits, even if the dividends paid or the retained earnings consist in whole or in part of profits or income generated in that other party. 3. (a) in the case of the Hong Kong Special Administrative Region, subject to the provisions of the laws of the Hong Kong Special Administrative Region relating to the deduction of a charge to the Hong Kong Special Administrative Region of the tax paid in an area outside the Hong Kong Special Administrative Region (which shall not affect the general principle of this Article), Canadian taxes which, in accordance with the laws of Canada and in accordance with this Agreement, are deducted directly or by deduction of income Data from sources in Canada from a person established in the Hong Kong Special Administrative Region shall be granted to the Hong Kong Special Administrative Region as an account of the tax payable on such income. provided that the credit so granted does not exceed the amount of tax of the Hong Kong Special Administrative Region, calculated for such income in accordance with the tax legislation of the Hong Kong Special Administrative Region. 3. It goes without saying that the concept of `profits` in Article 10(6) (dividends) does not include commercial profits attributable to a permanent establishment of a Contracting Party, or income from the trade in immovable property in a Party which has been reinvested in that Party, in accordance with the law of that Party. 3.
Paragraphs 1 and 2 shall not apply to income from activities carried out by a person residing in the other Party in connection with a visit of a non-profit organisation of the other Contracting Party to the first Contracting Party, where the visit is wholly or mainly supported by public funds. . . .