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of <h1>Enterprise Profits Taxed Only in State of Origin Unless Permanent Establishment Exists; Deductions Allowed with Exceptions</h1> Profits of an enterprise from one Contracting State are taxable only in that State unless the enterprise operates in the other Contracting State through a permanent establishment. In such cases, only profits attributable to that establishment may be taxed in the other State. Deductions are allowed for expenses incurred for the permanent establishment, excluding certain payments to the head office or other offices, such as royalties or commissions. Customary apportionment methods for determining profits may be used if consistent with the Article's principles. Profits from mere purchasing activities are not attributed to the permanent establishment. Consistent profit determination methods should be applied annually unless justified otherwise.
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