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of <h1>Understanding Taxation of Business Profits Under Article 7 of the US Double Tax Avoidance Agreement</h1> Article 7 of the Double Tax Avoidance Agreement (DTAA) between the USA and another contracting state addresses the taxation of business profits. Profits of an enterprise are taxable only in its home state unless it operates through a permanent establishment in the other state. In such cases, only profits attributable to the permanent establishment, similar sales, or business activities in the other state are taxable there. Profits are determined as if the establishment were an independent entity, with allowable deductions for business-related expenses. Certain payments between the establishment and its head office are excluded from deductions. Profits from mere purchases are not attributed to the establishment.
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