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of <h1>Enterprise Profits Taxable in State of Origin Unless Permanent Establishment Exists; Consistent Profit Determination Method Required Annually.</h1> The profits of an enterprise from one Contracting State are taxable only in that State unless the enterprise operates in the other State through a permanent establishment. In such cases, only profits attributable to the permanent establishment may be taxed in the other State. Profits should reflect what the establishment would earn as an independent entity. Deductions for expenses incurred for the permanent establishment are allowed, excluding certain payments like royalties or commissions to the head office. Profits cannot be attributed solely due to the purchase of goods. The method for determining profits should remain consistent annually unless justified otherwise.
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