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of <h1>Article 7 of DTAA: Tax Only Home State Profits Unless Permanent Establishment Exists; Independent Entity Approach Applied</h1> Article 7 of the Double Tax Avoidance Agreement (DTAA) between the Portuguese Republic and another Contracting State addresses the taxation of business profits. It stipulates that an enterprise's profits 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, related sales, or similar business activities in the other state may be taxed there. Profits are attributed as if the permanent establishment were an independent entity, with allowable deductions for incurred expenses. Consistent profit determination methods are required unless justified otherwise, and specific income items governed by other articles remain unaffected.
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