https://www.taxtmi.com/acts?id=4965 Profits of an enterprise are taxable only in the State of residence unless business is carried on in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Profits must be attributed as if the permanent establishment were a distinct and separate enterprise dealing independently; deductible expenses incurred for its purposes are allowed subject to local tax law, but deductions for payments to the head office or other offices (royalties, fees, commissions, management charges, interest) are disallowed. en-us Sat, 19 Jan 2008 22:45:54 +0530 Sat, 07 Dec 2024 11:48:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4965 Profits of an enterprise are taxable only in the State of residence unless business is carried on in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Profits must be attributed as if the permanent establishment were a distinct and separate enterprise dealing independently; deductible expenses incurred for its purposes are allowed subject to local tax law, but deductions for payments to the head office or other offices (royalties, fees, commissions, management charges, interest) are disallowed. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4965