https://www.taxtmi.com/acts?id=5478 Profits of an enterprise are taxable in the State of residence unless it carries on business in the other State through a permanent establishment, in which case only profits attributable to that permanent establishment, related sales or similar activities may be taxed there. Profits attributable to the permanent establishment are determined as if it were a separate enterprise dealing independently, with estimation permitted if precise determination is impracticable. Deductions include expenses incurred for the permanent establishment subject to local law, but not non reimbursement payments between the permanent establishment and head office such as royalties, fees, commissions, management charges or, except for banks, interest; mere purchase of goods does not create attributable profits. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 18 Nov 2024 11:03:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5478 Profits of an enterprise are taxable in the State of residence unless it carries on business in the other State through a permanent establishment, in which case only profits attributable to that permanent establishment, related sales or similar activities may be taxed there. Profits attributable to the permanent establishment are determined as if it were a separate enterprise dealing independently, with estimation permitted if precise determination is impracticable. Deductions include expenses incurred for the permanent establishment subject to local law, but not non reimbursement payments between the permanent establishment and head office such as royalties, fees, commissions, management charges or, except for banks, interest; mere purchase of goods does not create attributable profits. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5478