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of <h1>Article 7 of Mongolia's DTAA: Tax Business Profits Only if Permanent Establishment Exists; Consistent Profit Calculation Required</h1> Article 7 of the Double Tax Avoidance Agreement (DTAA) between Mongolia and another Contracting State addresses the taxation of business profits. Profits from an enterprise 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 that permanent establishment, related sales, or similar activities are taxable in the other state. Profits should be calculated as if the permanent establishment were an independent entity, allowing for deductions of relevant expenses. The method for determining profits must be consistent annually unless justified otherwise, and separate income items are governed by other Articles.
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