https://www.taxtmi.com/acts?id=5385 are taxable in the State of residence unless the enterprise operates in the other Contracting State through a permanent establishment, in which case taxable profits are limited to those attributable to that permanent establishment or related sales and activities. Profits must be attributed as if the permanent establishment were a distinct and separate enterprise dealing independently, allowing deductions for expenses incurred for the permanent establishment subject to local tax law limits, but excluding non reimbursed intercompany royalties, fees, commissions, management charges and, except for banks, interest. Customary apportionment methods are permissible if consistent with the Article and attribution methods should be applied consistently. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 05 Mar 2009 12:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5385 are taxable in the State of residence unless the enterprise operates in the other Contracting State through a permanent establishment, in which case taxable profits are limited to those attributable to that permanent establishment or related sales and activities. Profits must be attributed as if the permanent establishment were a distinct and separate enterprise dealing independently, allowing deductions for expenses incurred for the permanent establishment subject to local tax law limits, but excluding non reimbursed intercompany royalties, fees, commissions, management charges and, except for banks, interest. Customary apportionment methods are permissible if consistent with the Article and attribution methods should be applied consistently. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5385