Permanent establishment allocation: only profits attributable to the PE may be taxed where it operates abroad.

Taxation of an enterprise's business profits is reserved to the State of residence except where the enterprise operates in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Attribution follows the separate and independent enterprise principle, permitting deductions for expenses incurred for the permanent establishment's business under the taxing State's law. Customary apportionment methods may be used if consistent with this Article; purchases of goods alone do not create attributable profits, and the profit attribution method should be applied consistently year to year.

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