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of <h1>Enterprise Profits Taxable Only in Home State Unless Through Permanent Establishment; Deductions Allowed Except Certain Payments</h1> The profits of an enterprise from one contracting state are taxable only in that state unless it operates through a permanent establishment in another state. Profits attributed to such an establishment are treated as if it were an independent enterprise. Deductions for expenses incurred by the permanent establishment are allowed, except for payments like royalties or interest to the head office, unless it is a banking enterprise. Profits from mere purchases by the establishment are not attributed to it. The method for determining profits should remain consistent annually unless justified otherwise. Separate income items are governed by other agreement articles.
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