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of <h1>Taxation of Enterprise Profits Limited to Permanent Establishments in Foreign States Under Specific Tax Treaty Rules.</h1> The profits of an enterprise from one Contracting State are taxable only in that State unless it operates in the other Contracting State through a permanent establishment. In such cases, only the profits attributable to the permanent establishment may be taxed in the other State. Profits should be attributed as if the establishment were an independent enterprise. Expenses incurred for business purposes of the permanent establishment are deductible. No profits are attributed for mere purchase activities. The method for determining profits should remain consistent annually unless justified otherwise. Separate income items in other articles remain unaffected by these provisions.
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