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of <h1>Article 7 of DTAA: Business profits taxed in home state unless tied to a permanent establishment in another state.</h1> Article 7 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of business profits. Profits of an enterprise are taxable only in its home state unless it operates through a permanent establishment in the other state, in which case only profits attributable to that establishment may be taxed there. Profits attributed to a permanent establishment should reflect those of a distinct, independent entity, with allowable deductions for relevant expenses. Customary profit apportionment methods are permitted if they align with the Article's principles. Profits from mere purchasing activities are excluded from attribution, and consistent yearly profit determination methods are required unless justified otherwise.
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