Business profits allocation: permanent establishment profits taxable in host State only as attributable to that permanent establishment. 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. Attribution treats the permanent establishment as a distinct and separate enterprise under similar conditions. Deductions for expenses, including executive and general administrative costs, are allowed subject to the host State's tax law; no profits are attributed by reason only of purchases of goods. The method for attribution must be applied consistently 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.
Business profits allocation: permanent establishment profits taxable in host State only as attributable to that permanent establishment.
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. Attribution treats the permanent establishment as a distinct and separate enterprise under similar conditions. Deductions for expenses, including executive and general administrative costs, are allowed subject to the host State's tax law; no profits are attributed by reason only of purchases of goods. The method for attribution must be applied consistently year to year.
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