Business profits taxation tied to permanent establishment attribution determines which profits a State may tax. Profits of an enterprise are taxable only in its 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, related sales of the same or similar goods, or similar business activities may be taxed there; attribution must reflect profits the establishment would make as a distinct and separate enterprise and permit deduction of expenses incurred for its business.
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 taxation tied to permanent establishment attribution determines which profits a State may tax.
Profits of an enterprise are taxable only in its 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, related sales of the same or similar goods, or similar business activities may be taxed there; attribution must reflect profits the establishment would make as a distinct and separate enterprise and permit deduction of expenses incurred for its business.
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 
