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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Business Profits Taxed Based on Permanent Establishment Location with Mutual Agreement to Prevent Double Taxation</h1> The statutory provision addresses taxation of business profits under a Double Tax Avoidance Agreement (DTAA) based on the OECD Model. Profits are primarily taxable in the enterprise's home state, but can be taxed in the other state if a permanent establishment exists. The provision outlines principles for attributing profits to a permanent establishment, considering functions, assets, and risks, and includes mechanisms to prevent double taxation through mutual adjustments by competent authorities.
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