Permanent establishment: profits attributable to it may be taxed where the PE operates under an arm's-length attribution method. Profits of an enterprise are taxable only in its Contracting State unless it carries on business in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Such profits are determined by treating the permanent establishment as a distinct and separate enterprise operating on the same or similar conditions and dealing independently, permitting deductions for expenses incurred for the permanent establishment under the taxation laws of the Contracting State, while excluding mere purchase activities and without affecting income governed by other Articles.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Permanent establishment: profits attributable to it may be taxed where the PE operates under an arm's-length attribution method.
Profits of an enterprise are taxable only in its Contracting State unless it carries on business in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Such profits are determined by treating the permanent establishment as a distinct and separate enterprise operating on the same or similar conditions and dealing independently, permitting deductions for expenses incurred for the permanent establishment under the taxation laws of the Contracting State, while excluding mere purchase activities and without affecting income governed by other Articles.
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