https://www.taxtmi.com/acts?id=4817 Profits are taxable in the enterprise's State of residence unless the enterprise operates in the other State through a permanent establishment, in which case only profits attributable to that permanent establishment and sales of similar goods in that State may be taxed there. Profits attributable to the permanent establishment are determined as if it were a distinct and separate enterprise under similar conditions. Deductions are allowed for expenses incurred for the permanent establishment's business, but payments to or from the head office (other than reimbursement of actual expenses) for royalties, fees, commissions, management services, or interest (except for banking) are excluded. Apportionment methods customary in a Contracting State are permissible if they conform to these principles; purchases alone do not give rise to attributed profits, and the attribution method should be applied consistently year by year. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 05 Mar 2009 12:21:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4817 Profits are taxable in the enterprise's State of residence unless the enterprise operates in the other State through a permanent establishment, in which case only profits attributable to that permanent establishment and sales of similar goods in that State may be taxed there. Profits attributable to the permanent establishment are determined as if it were a distinct and separate enterprise under similar conditions. Deductions are allowed for expenses incurred for the permanent establishment's business, but payments to or from the head office (other than reimbursement of actual expenses) for royalties, fees, commissions, management services, or interest (except for banking) are excluded. Apportionment methods customary in a Contracting State are permissible if they conform to these principles; purchases alone do not give rise to attributed profits, and the attribution method should be applied consistently year by year. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4817