Business profits and permanent establishment: only profits attributable to the establishment may be taxed in the host State. Business profits 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 may be taxed there. Such profits are to be determined as if the permanent establishment were a distinct and separate enterprise operating under similar conditions, allowing deductions for expenses incurred for the permanent establishment, subject to the taxing State's law and limitations, and excluding attribution of profit merely from purchases of goods.
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 and permanent establishment: only profits attributable to the establishment may be taxed in the host State.
Business profits 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 may be taxed there. Such profits are to be determined as if the permanent establishment were a distinct and separate enterprise operating under similar conditions, allowing deductions for expenses incurred for the permanent establishment, subject to the taxing State's law and limitations, and excluding attribution of profit merely from purchases of goods.
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