Business profits taxation: resident state exclusive unless profits are attributable to a permanent establishment, then taxed accordingly. Business profits are taxable only in the resident State unless an enterprise carries on business in the other Contracting 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 separate enterprise principle or reasonable estimation where necessary. Deductions for expenses, including executive and general administrative costs, are allowed consistent with the taxation laws of the State where the permanent establishment is situated. Apportionment methods customary in a State may be used if they accord with this Article; profits from purchases alone are not attributed to a permanent establishment.
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: resident state exclusive unless profits are attributable to a permanent establishment, then taxed accordingly.
Business profits are taxable only in the resident State unless an enterprise carries on business in the other Contracting 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 separate enterprise principle or reasonable estimation where necessary. Deductions for expenses, including executive and general administrative costs, are allowed consistent with the taxation laws of the State where the permanent establishment is situated. Apportionment methods customary in a State may be used if they accord with this Article; profits from purchases alone are not attributed to a permanent establishment.
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