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of <h1>Enterprise Profits Taxable Only in Origin State Unless Operating Abroad; Deductions Allowed with Exceptions for Payments</h1> Profits of an enterprise from a Contracting State are taxable only in that State unless it operates in another State through a permanent establishment. Profits attributable to such an establishment may be taxed in the other State. Deductions for expenses incurred for the business of the permanent establishment are allowed, but not for payments like royalties or commissions to the head office, except for banking enterprises. Profits can be apportioned according to customary practices, but no profits are attributed merely for purchasing goods. The method for determining profits should remain consistent annually unless justified otherwise. Other income items governed by separate Articles remain unaffected.
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