https://www.taxtmi.com/acts?id=5569 Profits of an enterprise are taxable only in its State 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 must be attributed as if the permanent establishment were a separate independent enterprise; reasonable estimates are permitted when precise determination is impracticable. Deductible are expenses incurred for the permanent establishment, but not amounts beyond reimbursement paid between the establishment and head office by way of royalties, fees, commissions, management charges or, except for banks, interest. No profits arise from mere purchases, and attribution methods should be consistent year to year. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 05 Mar 2009 11:40:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5569 Profits of an enterprise are taxable only in its State 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 must be attributed as if the permanent establishment were a separate independent enterprise; reasonable estimates are permitted when precise determination is impracticable. Deductible are expenses incurred for the permanent establishment, but not amounts beyond reimbursement paid between the establishment and head office by way of royalties, fees, commissions, management charges or, except for banks, interest. No profits arise from mere purchases, and attribution methods should be consistent year to year. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5569