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of <h1>Enterprises Taxed in Home State Unless Permanent Establishment Exists in Another State; Profits Attributed Separately</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. Profits attributable to such an establishment may be taxed in the other State. Profits should be attributed as if the establishment were a separate entity, with deductions allowed for expenses related to its operations. Customary apportionment methods can be used if aligned with the article's principles. No profits are attributed for mere purchases by the establishment. Consistent profit determination methods should be applied annually unless justified otherwise, without affecting provisions for separately dealt income items.
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