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of <h1>Article 7: Business Profits Taxed in Home State Unless Permanent Establishment Exists; Profit Apportionment Rules Apply Consistently.</h1> Under Article 7 of the Double Tax Avoidance Agreement between two Contracting States, business profits are taxable only in the enterprise's home state unless it operates through a permanent establishment in the other state. Profits attributable to such an establishment may be taxed in the host state. Deductions for expenses incurred for the permanent establishment are allowed, but not for payments like royalties or interest to the head office, except in banking. Customary profit apportionment methods are permitted if consistent with this Article. Profits from mere purchase activities are not attributed to the permanent establishment, and consistent profit determination methods must be used annually unless justified otherwise.
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