Business profits: home-state taxation unless attributable to a permanent establishment abroad, with profits computed as if a separate enterprise. Profits are taxable only in the State of the enterprise unless business is carried on through a permanent establishment in the other State, in which case only profits attributable to that permanent establishment may be taxed there. Attributed profits are those the permanent establishment would be expected to make as a distinct and separate enterprise under similar conditions. Deductions are allowed for expenses incurred for the permanent establishment's business subject to the taxing State's laws, with specified limits on inter-company charges and exceptions for banking interest.
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: home-state taxation unless attributable to a permanent establishment abroad, with profits computed as if a separate enterprise.
Profits are taxable only in the State of the enterprise unless business is carried on through a permanent establishment in the other State, in which case only profits attributable to that permanent establishment may be taxed there. Attributed profits are those the permanent establishment would be expected to make as a distinct and separate enterprise under similar conditions. Deductions are allowed for expenses incurred for the permanent establishment's business subject to the taxing State's laws, with specified limits on inter-company charges and exceptions for banking interest.
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