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of <h1>Enterprise Profits Taxable Only in Home State Unless Permanent Establishment Exists; Deductions Allowed for Related Expenses</h1> Profits of an enterprise in a Contracting State are taxable only in that State unless the enterprise operates in the other State through a permanent establishment. In such cases, only profits attributable to that establishment may be taxed in the other State. Deductions for expenses related to the permanent establishment are allowed, except for certain payments like royalties or interest to the head office. Profits can be apportioned based on customary practices, provided they align with the Article's principles. Profits from mere purchases by the establishment are not attributed to it, and consistent profit determination methods are required unless justified otherwise.
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