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of <h1>Article 7 of DTAA: Business Profits Taxable in Home State, Except for Permanent Establishments in Other State</h1> Article 7 of the Double Taxation Avoidance Agreement (DTAA) outlines the taxation of business profits between two contracting states. Profits are taxable only in the enterprise's home state unless it operates through a permanent establishment in the other state. In such cases, only profits attributable to the permanent establishment, similar sales, or activities in the other state are taxable there. Profits attributed to the permanent establishment should reflect what an independent enterprise would earn under similar conditions. Deductions for expenses are allowed, but not for payments like royalties or interest to the head office, except for banking enterprises. Customary profit apportionment methods are permitted if consistent with the article's principles.
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