Business profits taxation: residence-state taxation unless permanent establishment in other state yields attributable taxable profits. Profits of an enterprise are taxable only in its State of residence unless the enterprise carries on business through a permanent establishment in the other State, in which case only profits attributable to that permanent establishment may be taxed there. Attribution follows the separate enterprise principle, allowing deductions for expenses incurred for the permanent establishment's business subject to the host State's tax law, excluding profits from mere purchases, and applying a consistent attribution method year to year unless justified otherwise.
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: residence-state taxation unless permanent establishment in other state yields attributable taxable profits.
Profits of an enterprise are taxable only in its State of residence unless the enterprise carries on business through a permanent establishment in the other State, in which case only profits attributable to that permanent establishment may be taxed there. Attribution follows the separate enterprise principle, allowing deductions for expenses incurred for the permanent establishment's business subject to the host State's tax law, excluding profits from mere purchases, and applying a consistent attribution method year to year unless justified otherwise.
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