https://www.taxtmi.com/acts?id=5601 Profits of an enterprise are taxable in the other Contracting State only if derived through a permanent establishment, and only to the extent attributable to that PE. Profits attributable to a PE are determined as if the PE were a distinct and separate enterprise under similar conditions dealing independently. Expenses incurred for the PE, including executive and general administrative expenses, are allowable deductions under the taxing State's laws; purchases of goods do not by themselves create attributable profits. The attribution method must be applied consistently year to year, and other Articles govern separately dealt with income items. en-us Sat, 19 Jan 2008 22:45:54 +0530 Wed, 28 Aug 2024 16:42:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5601 Profits of an enterprise are taxable in the other Contracting State only if derived through a permanent establishment, and only to the extent attributable to that PE. Profits attributable to a PE are determined as if the PE were a distinct and separate enterprise under similar conditions dealing independently. Expenses incurred for the PE, including executive and general administrative expenses, are allowable deductions under the taxing State's laws; purchases of goods do not by themselves create attributable profits. The attribution method must be applied consistently year to year, and other Articles govern separately dealt with income items. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5601