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<h1>Business Profits Taxable Only in Home State Under DTAA Article 7, Unless Through Permanent Establishment</h1> Under Article 7 of the Double Tax Avoidance Agreement (DTAA) between Korea and another state, business profits of an enterprise are taxable only in the enterprise's home state unless it operates through a permanent establishment in the other state. Profits attributable to such a permanent establishment may be taxed in the other state. Profits are calculated as if the establishment were an independent entity, and relevant expenses are deductible according to local laws. No profits are attributed for mere purchasing activities. Profit attribution methods should remain consistent annually unless justified otherwise. Separate income items governed by other treaty articles remain unaffected by this article.