Business profits taxation: permanent establishment requirement confines taxation to profits attributable to that establishment under arm's length conditions. Profits of an enterprise of one Contracting State are taxable in the other State only if derived through a permanent establishment there and only to the extent attributable to that permanent establishment; attribution treats the permanent establishment as a distinct and separate enterprise operating under similar conditions and dealing independently. Deductions are allowed for expenses incurred for the purposes of the permanent establishment subject to the source State's taxation law; no profits are attributed solely for purchases of goods, attribution methods should be applied consistently year by year, and other treaty provisions for specific income items prevail.
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Business profits taxation: permanent establishment requirement confines taxation to profits attributable to that establishment under arm's length conditions.
Profits of an enterprise of one Contracting State are taxable in the other State only if derived through a permanent establishment there and only to the extent attributable to that permanent establishment; attribution treats the permanent establishment as a distinct and separate enterprise operating under similar conditions and dealing independently. Deductions are allowed for expenses incurred for the purposes of the permanent establishment subject to the source State's taxation law; no profits are attributed solely for purchases of goods, attribution methods should be applied consistently year by year, and other treaty provisions for specific income items prevail.
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