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of <h1>Business Profits Taxed Only if Attributed to Permanent Establishment Under DTAA; Consistent Annual Profit Calculation Required.</h1> The Double Tax Avoidance Agreement (DTAA) between two contracting states outlines that business profits of an enterprise from one state can be taxed in the other state only if derived through a permanent establishment there, and only to the extent attributable to that establishment's activities. Profits should be calculated as if the establishment were an independent entity, with allowable deductions for expenses incurred for its purposes. Profits from mere purchasing activities are not attributed to the establishment. The method for determining profits must remain consistent annually unless justified otherwise. Separate income items addressed in other agreement articles remain unaffected by this article.
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