Taxation of business profits: permanent establishment profits attributed as if a separate independent enterprise. Taxation of business profits grants primary taxing rights to the State of the enterprise and allows the State of a permanent establishment to tax profits attributable to it. Attributable profits are computed as if the permanent establishment were a distinct and separate enterprise operating under similar conditions and dealing independently. Deductible expenses incurred for the permanent establishment are allowed whether incurred locally or elsewhere. No profit is attributed solely for purchases of goods. The method of attribution is to be applied consistently unless good reason warrants change, and other Article provisions for specific income items are unaffected.
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.
Taxation of business profits: permanent establishment profits attributed as if a separate independent enterprise.
Taxation of business profits grants primary taxing rights to the State of the enterprise and allows the State of a permanent establishment to tax profits attributable to it. Attributable profits are computed as if the permanent establishment were a distinct and separate enterprise operating under similar conditions and dealing independently. Deductible expenses incurred for the permanent establishment are allowed whether incurred locally or elsewhere. No profit is attributed solely for purchases of goods. The method of attribution is to be applied consistently unless good reason warrants change, and other Article provisions for specific income items are unaffected.
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