Business profits taxation: permanent establishment determines taxable profits attributable to a foreign fixed place of business. Business profits are taxable only in the enterprise's State of residence unless the enterprise carries on business in the other State through a permanent establishment; where such an establishment exists, only profits attributable to it may be taxed there. Attribution is made by treating the permanent establishment as a separate enterprise under similar conditions, allowing deductions for expenses incurred for its purposes subject to local tax law limits, excluding mere purchases of goods, and applying the same method year to year unless good reason exists to change it.
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: permanent establishment determines taxable profits attributable to a foreign fixed place of business.
Business profits are taxable only in the enterprise's State of residence unless the enterprise carries on business in the other State through a permanent establishment; where such an establishment exists, only profits attributable to it may be taxed there. Attribution is made by treating the permanent establishment as a separate enterprise under similar conditions, allowing deductions for expenses incurred for its purposes subject to local tax law limits, excluding mere purchases of goods, and applying the same method year to year unless good reason exists to change it.
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