Permanent establishment: business profits attributable to it may be taxed in the host state to that extent. Profits of an enterprise are taxable only in its State of residence unless it carries on business in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Such attributable profits are determined as if the permanent establishment were a distinct and separate enterprise dealing independently, allowing deductions for expenses incurred for its business in accordance with the host State's tax law, with consistent application year to year.
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: business profits attributable to it may be taxed in the host state to that extent.
Profits of an enterprise are taxable only in its State of residence unless it carries on business in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Such attributable profits are determined as if the permanent establishment were a distinct and separate enterprise dealing independently, allowing deductions for expenses incurred for its business in accordance with the host State's tax law, with consistent application year to year.
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