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of <h1>Article 7 of DTAA: Business Profits Taxed in Origin State Unless Permanent Establishment Exists in Other State</h1> Article 7 of the Double Taxation Avoidance Agreement (DTAA) between two contracting states addresses the taxation of business profits. Profits of an enterprise are taxable only in the state of origin unless the enterprise operates through a permanent establishment in the other state, in which case only the profits attributable to that establishment may be taxed there. Profits are determined as if the establishment is an independent entity, with deductions allowed for expenses incurred for its purposes. Profits from mere purchase activities are not attributed to the establishment. Consistency in profit determination is required unless justified otherwise, and specific income items addressed in other articles are not affected by this article.
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