https://www.taxtmi.com/acts?id=5780 Profits are taxable in the resident State unless an enterprise carries on business in the other State through a permanent establishment; then only profits attributable to the PE may be taxed there. Attribution follows the distinct-and-separate enterprise (arm's length) principle. Deductible expenses incurred for the PE are allowed, but payments from the PE to head office (other than reimbursements) for royalties, fees, commissions, management charges or, except for banks, interest, are not deductible nor are reciprocal charges taken into account. Customary apportionment, no attribution for mere purchases, and consistent year to year methods are permitted. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 05 Mar 2009 12:07:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5780 Profits are taxable in the resident State unless an enterprise carries on business in the other State through a permanent establishment; then only profits attributable to the PE may be taxed there. Attribution follows the distinct-and-separate enterprise (arm's length) principle. Deductible expenses incurred for the PE are allowed, but payments from the PE to head office (other than reimbursements) for royalties, fees, commissions, management charges or, except for banks, interest, are not deductible nor are reciprocal charges taken into account. Customary apportionment, no attribution for mere purchases, and consistent year to year methods are permitted. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5780