https://www.taxtmi.com/acts?id=5962 An enterprise of a Contracting State is taxable in the other State only if it carries on business there through a permanent establishment, and then only for profits attributable to that PE, including sales of similar goods and similar business activities. Profits must be attributed as if the PE were a distinct and separate enterprise operating under similar conditions, with allowable deductions for PE expenses. Customary apportionment methods may be used if they align with the Article's principles, purchases alone do not create attributable profits, and the method of attribution should be used consistently year to year. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 05 Mar 2009 11:37:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5962 An enterprise of a Contracting State is taxable in the other State only if it carries on business there through a permanent establishment, and then only for profits attributable to that PE, including sales of similar goods and similar business activities. Profits must be attributed as if the PE were a distinct and separate enterprise operating under similar conditions, with allowable deductions for PE expenses. Customary apportionment methods may be used if they align with the Article's principles, purchases alone do not create attributable profits, and the method of attribution should be used consistently year to year. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5962