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of <h1>Profits Taxable Only in State of Origin Unless Permanent Establishment Exists, Reflecting Independent Operations Under Similar Conditions</h1> The profits of an enterprise from a Contracting State are taxable only in that State unless the enterprise operates in the other Contracting State through a permanent establishment. In such cases, only profits attributable to that permanent establishment may be taxed in the other State. Profits attributed to a permanent establishment should reflect those expected if it operated independently under similar conditions. Deductible expenses include those incurred for the permanent establishment's purposes. Customary profit apportionment methods may be used if aligned with this Article's principles. Profits from mere purchasing activities are not attributed to the permanent establishment. Consistent profit attribution methods should be used annually unless justified otherwise. Other income items addressed in separate Articles remain unaffected by this Article.
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