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of <h1>Enterprise Profits Taxable Only in Contracting State Unless Permanent Establishment Exists; Deductions Allowed with Exceptions</h1> Profits of an enterprise from a Contracting State are taxable only in that State unless the enterprise operates in the other Contracting State through a permanent establishment. Profits attributable to such an establishment can be taxed in the other State. Deductions for business-related expenses are allowed, but not for payments like royalties or interest to the head office, except for banking enterprises. Profits may be apportioned based on customary practices, and consistent methods should be used annually unless justified otherwise. Separate income items covered by other Articles remain unaffected by this Article.
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