Introducing the “In Favour Of” filter in Case Laws.
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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Taxation of Enterprise Profits: Only Taxable in State of Establishment Unless Operating Through Permanent Establishment in Another State.</h1> The profits of an enterprise from a Contracting State are taxable only in that State unless it operates in the other Contracting State through a permanent establishment. In such cases, only profits attributable to that establishment can be taxed in the other State. Profits should be calculated as if the establishment were an independent entity, with allowable deductions for expenses incurred for its purposes. No profits are attributed merely for purchasing goods. The method of determining profits should remain consistent annually unless justified otherwise. If profits include income addressed in other Articles, those provisions remain unaffected.
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