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of <h1>Enterprise Profits Taxable in Home State Unless Operating Through Permanent Establishment in Another; Deductions Limited</h1> The 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 may be taxed in the other State. Deductions for expenses related to the permanent establishment are allowed, excluding payments for royalties, fees, commissions, or interest to the head office. No profits are attributed to a permanent establishment solely for purchasing goods. Profits must be consistently determined unless justified otherwise, and apportionment methods should align with the article's principles.
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