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of <h1>Profits Taxable Only in State of Origin Unless Permanent Establishment Exists; Consistent Profit Determination Required Annually</h1> The profits of an enterprise from a Contracting State are taxable only in that State unless the enterprise operates in another Contracting State through a permanent establishment. In such cases, only profits attributable to that establishment may be taxed in the other State. Profits attributed to a permanent establishment should reflect what it would earn as an independent entity. Deductions for expenses incurred for the establishment are allowed, except for certain payments to the enterprise's head office or other offices. Profits from mere purchasing activities by the establishment are not attributed. The method of determining profits should remain consistent annually unless justified otherwise.
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