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of <h1>Enterprise Profits Taxed Solely in Home State Unless Permanent Establishment Exists; Deductions Allowed for Business Expenses</h1> The profits of an enterprise from one Contracting State are taxable only in that State unless the enterprise operates in the other State through a permanent establishment. In such cases, only profits attributable to the permanent establishment, related sales, or similar business activities in the other State may be taxed there. Profits attributed to the permanent establishment should reflect what it would earn as an independent entity, allowing for reasonable estimation if precise calculation is difficult. Deductions for business expenses are permitted, excluding profits from mere purchasing activities for export. Consistent profit attribution methods should be applied annually unless justified otherwise.
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