https://www.taxtmi.com/acts?id=4708 Article 7 allocates taxing rights for business profits by reference to the existence of a permanent establishment; only profits attributable to that permanent establishment may be taxed by the State where it is situated. Profits are attributed as if the permanent establishment were a distinct and separate enterprise dealing independently, with allowable deductions for expenses incurred for the permanent establishment's business. Where application of the separate-enterprise standard is impossible or unreasonable, profits may be apportioned or estimated on a reasonable basis consistent with the Article; purchases of goods alone do not give rise to attributed profits. en-us Sat, 19 Jan 2008 22:45:54 +0530 Wed, 20 Nov 2024 14:25:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4708 Article 7 allocates taxing rights for business profits by reference to the existence of a permanent establishment; only profits attributable to that permanent establishment may be taxed by the State where it is situated. Profits are attributed as if the permanent establishment were a distinct and separate enterprise dealing independently, with allowable deductions for expenses incurred for the permanent establishment's business. Where application of the separate-enterprise standard is impossible or unreasonable, profits may be apportioned or estimated on a reasonable basis consistent with the Article; purchases of goods alone do not give rise to attributed profits. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4708