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of <h1>Enterprise Profits Taxable Only in Home State Unless Permanent Establishment Exists in Other State</h1> The profits of an enterprise from one Contracting State are taxable only in that State unless the enterprise operates in the other Contracting State through a permanent establishment. In such cases, only profits attributable to that permanent establishment may be taxed in the other State. Profits are determined as if the establishment is an independent entity, with allowable deductions for business expenses. No profits are attributed merely from purchasing goods. If profit determination is difficult, local laws apply as long as they align with this Article. Insurance profits and specific income items are governed by separate provisions. Residents entitled to business profits through trust estates are deemed to have a permanent establishment in the other State.
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