Business profits taxable in residence state unless a permanent establishment creates attributable taxable profits in the other state. Profits of an enterprise are taxable only in the State of residence unless the enterprise carries on business in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment, sales of the same or similar goods, or other similar activities may be taxed by the other State; attribution must treat the permanent establishment as a distinct and separate enterprise and allow deductions for expenses incurred for its purposes, subject to domestic law, with consistent year to year application.
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 taxable in residence state unless a permanent establishment creates attributable taxable profits in the other state.
Profits of an enterprise are taxable only in the State of residence unless the enterprise carries on business in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment, sales of the same or similar goods, or other similar activities may be taxed by the other State; attribution must treat the permanent establishment as a distinct and separate enterprise and allow deductions for expenses incurred for its purposes, subject to domestic law, with consistent year to year application.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
