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of <h1>Enterprise Profits Taxable in State of Operation Unless Permanent Establishment Exists; Follow Article Principles for Apportionment</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 the profits attributable to that establishment may be taxed in the other State. Profits attributed to a permanent establishment should reflect what it would earn as an independent entity, with allowable deductions for business expenses. Customary methods of profit apportionment are permissible if they align with the Article's principles. Profits from mere purchasing activities are not attributed to the establishment, and consistent profit determination methods should be used annually unless justified otherwise.
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