Permanent establishment: only profits attributable to the permanent establishment may be taxed in the host state. Profits of an enterprise are taxable only in its State unless business is carried on in the other State through a permanent establishment; then only profits attributable to that permanent establishment may be taxed there, determined by treating the permanent establishment as a distinct and separate enterprise, allowing deductions for expenses incurred for its purposes and excluding attribution merely for purchases.
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.
Permanent establishment: only profits attributable to the permanent establishment may be taxed in the host state.
Profits of an enterprise are taxable only in its State unless business is carried on in the other State through a permanent establishment; then only profits attributable to that permanent establishment may be taxed there, determined by treating the permanent establishment as a distinct and separate enterprise, allowing deductions for expenses incurred for its purposes and excluding attribution merely for purchases.
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