https://www.taxtmi.com/acts?id=5931 Business profits are taxable in the enterprise's residence State unless the enterprise carries on business through a permanent establishment in the other Contracting State; only profits attributable to that permanent establishment may be taxed there. Attribution follows the principle that the permanent establishment is treated as a distinct and separate enterprise under similar conditions, with reasonable estimation allowed where precise determination is impracticable. Deductible expenses include those incurred for the permanent establishment's business, subject to domestic disallowance rules, and mere purchases by the permanent establishment do not create attributable profits. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 05 Mar 2009 11:48:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5931 Business profits are taxable in the enterprise's residence State unless the enterprise carries on business through a permanent establishment in the other Contracting State; only profits attributable to that permanent establishment may be taxed there. Attribution follows the principle that the permanent establishment is treated as a distinct and separate enterprise under similar conditions, with reasonable estimation allowed where precise determination is impracticable. Deductible expenses include those incurred for the permanent establishment's business, subject to domestic disallowance rules, and mere purchases by the permanent establishment do not create attributable profits. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5931