Business profits: taxation tied to permanent establishment, with profits attributed as if the establishment were a separate enterprise.

Profits of an enterprise are taxable only in its State of residence unless the enterprise 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. Attributable profits are determined as if the permanent establishment were a distinct and separate enterprise engaged in similar activities under similar conditions, allowing deductible expenses incurred for the permanent establishment but disallowing certain payments to the head office; customary apportionment and estimation by tax authorities are permitted consistent with the Article's principles.

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