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of <h1>Enterprise Profits Taxed Only in Contracting State Unless Permanent Establishment Exists Elsewhere, Reflecting Independent Earnings</h1> Profits of an enterprise from a Contracting State are taxable only in that State unless business is conducted in another State through a permanent establishment. Profits attributable to such an establishment can be taxed in the other State. The establishment's profits should reflect what it would earn if it were independent, with allowable deductions for business-related expenses. Customary profit apportionment methods may be used if aligned with this Article's principles. Profits from mere purchasing activities are not attributed to the establishment. Consistent profit determination methods should be applied annually unless justified otherwise. Separate income items are governed by relevant Articles.
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