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of <h1>Article 7: Taxation of Business Profits Under DTAA; Permanent Establishment Rules and Profit Attribution Explained</h1> Article 7 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States 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 are taxable there. The article details how profits are attributed, allowing deductions for business expenses but excluding certain payments like royalties and interest. It also specifies that mere purchase activities by a permanent establishment do not attribute profits to it, and other income items covered by separate articles remain unaffected.
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