https://www.taxtmi.com/acts?id=4249 Profits of an enterprise are taxable only in its State of residence unless the enterprise carries on business in the other Contracting State through a permanent establishment; profits attributable to that permanent establishment may be taxed only in the State where it is situated. Attribution must reflect the profits the permanent establishment would make as a distinct and separate enterprise under similar conditions, with reasonable computation allowed where precise determination is impracticable. Deductions for expenses incurred for the permanent establishment are permitted subject to local disallowance rules; customary apportionment methods remain permissible if consistent with this Article. Purchases by the permanent establishment do not by themselves give rise to attributed profits, attribution methods should be applied consistently, and other Convention provisions govern separately dealt-with income. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 04 Nov 2024 16:38:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4249 Profits of an enterprise are taxable only in its State of residence unless the enterprise carries on business in the other Contracting State through a permanent establishment; profits attributable to that permanent establishment may be taxed only in the State where it is situated. Attribution must reflect the profits the permanent establishment would make as a distinct and separate enterprise under similar conditions, with reasonable computation allowed where precise determination is impracticable. Deductions for expenses incurred for the permanent establishment are permitted subject to local disallowance rules; customary apportionment methods remain permissible if consistent with this Article. Purchases by the permanent establishment do not by themselves give rise to attributed profits, attribution methods should be applied consistently, and other Convention provisions govern separately dealt-with income. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4249