Business profits allocation: taxable in resident state unless attributable to a permanent establishment in the other state. Business profits are taxable only in the resident State except where an enterprise carries on business through a permanent establishment in the other State; only profits attributable to that PE may be taxed there. Profits attributable to the PE are to be determined as if the PE were a distinct and separate enterprise dealing independently, with deductions allowed for expenses incurred for the PE, subject to domestic law limits.
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.
Business profits allocation: taxable in resident state unless attributable to a permanent establishment in the other state.
Business profits are taxable only in the resident State except where an enterprise carries on business through a permanent establishment in the other State; only profits attributable to that PE may be taxed there. Profits attributable to the PE are to be determined as if the PE were a distinct and separate enterprise dealing independently, with deductions allowed for expenses incurred for the PE, subject to domestic law limits.
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