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of <h1>Article 7 of DTAA: Taxation of Business Profits Only on Permanent Establishment Basis with Consistent Profit Determination</h1> Article 7 of the Double Taxation Avoidance Agreement (DTAA) between Thailand and another Contracting State outlines 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 can be taxed there. Profits attributed to a permanent establishment should reflect what it would earn as an independent entity, with allowable deductions for business-related expenses. The method for determining profits should be consistent annually unless justified otherwise, and this article does not override other specific income provisions in the agreement.
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