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of <h1>Profits Taxable Only in State of Permanent Establishment Unless Operating in Another State Under Specific Conditions</h1> The profits of an enterprise from one contracting state are taxable only in that state unless it operates in the other state through a permanent establishment. In such cases, only the profits attributable to that permanent establishment can be taxed in the other state. Profits should be attributed as if the permanent establishment were an independent entity, with allowable deductions for expenses incurred for its purposes. No profits are attributed merely for purchasing goods. The method for determining profits should remain consistent annually unless justified otherwise. If profits include income covered by other articles, those provisions remain unaffected.
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