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of <h1>Article 7 of DTAA: Business Profits Taxed Only in State of Origin Unless Permanent Establishment Exists in Other State.</h1> Article 7 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of business profits. Profits from an enterprise in one State are taxable only there, unless the enterprise operates in the other State through a permanent establishment. In such cases, only profits attributable to the permanent establishment can be taxed in the other State. Deductions for expenses related to the permanent establishment are allowed, except for certain payments like royalties or interest, unless they are reimbursements. Profits attributed to a permanent establishment should be determined consistently each year, unless justified otherwise.
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