Permanent establishment: profits taxable in the other State only to the extent attributable under profit attribution rules. Business profits are taxable in the State of residence except to the extent attributable to a permanent establishment in the other Contracting State; such PE profits are those the PE would expect to earn as a distinct and separate enterprise under similar conditions, with allowable deductions for expenses incurred for the PE in accordance with the domestic law where the PE is situated.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Permanent establishment: profits taxable in the other State only to the extent attributable under profit attribution rules.
Business profits are taxable in the State of residence except to the extent attributable to a permanent establishment in the other Contracting State; such PE profits are those the PE would expect to earn as a distinct and separate enterprise under similar conditions, with allowable deductions for expenses incurred for the PE in accordance with the domestic law where the PE is situated.
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