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of <h1>Profits Taxable in Another State Only Through Permanent Establishment; Independent Entity Rule Applies; Consistent Annual Profit Method Required.</h1> The profits of an enterprise from one state are taxable only in that state unless the enterprise conducts business in the other state through a permanent establishment. Profits attributable to such an establishment may be taxed in the other state. Profits are determined as if the establishment were an independent entity. Deductions for expenses incurred for the permanent establishment are allowed, but payments like royalties or interest to the head office are not deductible. Profits from mere purchasing activities are not attributed to the permanent establishment. The method for determining profits should remain consistent annually unless justified otherwise.
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