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of <h1>Enterprise Profits Taxed Only in Home State Unless Permanent Establishment Exists; Consistent Methods Required Annually</h1> Profits of an enterprise from one Contracting State are taxable only in that State unless the enterprise operates through a permanent establishment in the other State. Profits attributable to such an establishment or related sales and activities may be taxed in the other State. Profits must be determined as if the permanent establishment were an independent entity. Deductible expenses for the establishment are allowed, excluding certain payments to the head office. Profits cannot be attributed solely due to purchases by the establishment. Consistent methods must be used annually unless justified otherwise, and specific income items covered by other treaty articles remain unaffected.
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