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.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
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.
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