Business profits taxation: resident state primacy unless a permanent establishment gives taxing rights over attributable profits.

An enterprise's profits are taxable only in its resident State unless it carries on business in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there; such attributable profits are to be determined as those the permanent establishment would make as a distinct and separate enterprise, allowing deductions for expenses incurred for its purposes and applying customary apportionment methods consistent with this Article.

---

---

---