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.

---

---

---