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of <h1>Profits from Enterprises Taxed Only in State of Origin Unless Permanent Establishment Exists in Another State</h1> The profits of an enterprise from one Contracting State are taxable only in that State unless the enterprise operates in another Contracting State through a permanent establishment. Profits attributable to such an establishment are taxable in the other State. Profits must reflect what the establishment would earn independently, and deductions for relevant expenses are allowed. Customary profit apportionment methods may be used if consistent with the Article's principles. No profits are attributed to a permanent establishment merely for purchasing goods. Profit determination methods should remain consistent annually unless justified otherwise. Separate income items governed by other Articles remain unaffected.
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