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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 7 of DTAA: Business profits taxable in home state unless linked to permanent establishment in other state.</h1> Under Article 7 of the Double Taxation Avoidance Agreement (DTAA) between Nepal and another Contracting State, business profits are taxable only in the enterprise's home state unless it operates through a permanent establishment in the other state. Profits attributed to such an establishment can be taxed in the other state. Deductions for expenses incurred for the establishment are allowed, excluding certain payments like royalties and management fees. Profits are attributed based on customary apportionment methods, and no profits are attributed solely for purchasing goods. The attribution method should remain consistent annually unless justified otherwise. Other income items are governed by separate Articles.
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