https://www.taxtmi.com/acts?id=4190 Profits of an enterprise are taxable only in its State of residence unless it carries on business in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Attribution is on a distinct-and-separate enterprise basis, applied consistently year by year unless there is good reason to change. Deductible expenses incurred for the permanent establishment's business are allowed under the law of the State where the permanent establishment is situated, and no profits are attributed merely for purchases; where precise determination is impracticable, domestic law may be applied consistent with these principles. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 25 Nov 2024 15:00:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4190 Profits of an enterprise are taxable only in its State of residence unless it carries on business in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Attribution is on a distinct-and-separate enterprise basis, applied consistently year by year unless there is good reason to change. Deductible expenses incurred for the permanent establishment's business are allowed under the law of the State where the permanent establishment is situated, and no profits are attributed merely for purchases; where precise determination is impracticable, domestic law may be applied consistent with these principles. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4190