https://www.taxtmi.com/acts?id=5901 Profits of a resident enterprise are taxable only in that State except profits attributable to a permanent establishment in the other Contracting State, which may be taxed there. Attributable profits are determined by treating the permanent establishment as a distinct and separate enterprise dealing independently, using a consistent method year to year unless justified otherwise; if correct attribution cannot be determined, profits may be estimated reasonably. Reasonable business expenses, including executive and general administrative expenses, are deductible, and mere purchase of goods does not create attributable profits. Other treaty provisions for specific income items prevail. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 05 Mar 2009 11:14:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5901 Profits of a resident enterprise are taxable only in that State except profits attributable to a permanent establishment in the other Contracting State, which may be taxed there. Attributable profits are determined by treating the permanent establishment as a distinct and separate enterprise dealing independently, using a consistent method year to year unless justified otherwise; if correct attribution cannot be determined, profits may be estimated reasonably. Reasonable business expenses, including executive and general administrative expenses, are deductible, and mere purchase of goods does not create attributable profits. Other treaty provisions for specific income items prevail. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5901