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of <h1>Taxation of Enterprise Profits Limited to Permanent Establishments per Convention; Consistent Profit Calculation Required.</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 establishment may be taxed in the other State. Profits should be calculated as if the establishment were an independent entity, with deductions allowed for relevant expenses. Profits cannot be attributed merely for purchasing goods. The same method for determining profits should be used consistently unless justified otherwise. Other income items covered by different articles of the Convention remain unaffected by these provisions.
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