https://www.taxtmi.com/acts?id=5355 Business profits are taxable in the State of residence unless an enterprise carries on business in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment or to sales of the same or similar goods may be taxed there; attribution follows the separate enterprise principle, allows reasonable estimation where necessary, admits deductions for establishment-related expenses under local tax law, permits customary apportionment consistent with these principles, excludes mere purchases from attribution, and requires year-to-year consistency absent good reason to change. en-us Sat, 19 Jan 2008 22:45:54 +0530 Wed, 27 Nov 2024 15:07:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5355 Business profits are taxable in the State of residence unless an enterprise carries on business in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment or to sales of the same or similar goods may be taxed there; attribution follows the separate enterprise principle, allows reasonable estimation where necessary, admits deductions for establishment-related expenses under local tax law, permits customary apportionment consistent with these principles, excludes mere purchases from attribution, and requires year-to-year consistency absent good reason to change. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5355