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of <h1>Article 7 of DTAA: Taxation Rules for Business Profits and Permanent Establishments Explained</h1> Article 7 of the Double Taxation Avoidance Agreement (DTAA) between two contracting states addresses the taxation of business profits. Profits from an enterprise are taxable only in its home state unless it operates through a permanent establishment in the other state. In such cases, only profits attributable to that establishment can be taxed in the other state. The profits attributed to the permanent establishment should reflect those of an independent entity engaged in similar activities. Deductions for business-related expenses are allowed, and profits from mere purchases by the establishment are not attributed to it. The profit attribution method should be consistent annually unless justified otherwise.
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