Permanent establishment: business profits attributable to a PE may be taxed in the state where the PE operates.

Profits of an enterprise are taxable only in its Contracting State unless business is carried on in the other State through a permanent establishment, in which case only profits directly or indirectly attributable to that permanent establishment may be taxed there; attribution follows the distinct and separate enterprise principle, allows deductions for expenses incurred for the permanent establishment, permits administrative estimation where information is lacking, requires consistent methods year to year unless justified, and excludes attribution for mere purchases, while not affecting insurance taxation or other Articles covering specific income items.

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