https://www.taxtmi.com/acts?id=6021 Profits of an enterprise are taxable only in its State of residence unless the enterprise carries on business in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Attributable profits are those the permanent establishment would earn as a distinct and separate enterprise dealing independently under similar conditions. Deductions are allowed for expenses incurred for the permanent establishment's business subject to local tax law limits; mere purchase of goods does not give rise to attributed profits. The same attribution method applies year to year unless justified otherwise, and other Articles govern separately dealt-with income items. en-us Sat, 19 Jan 2008 22:45:54 +0530 Wed, 04 Sep 2024 18:04:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6021 Profits of an enterprise are taxable only in its State of residence unless the enterprise carries on business in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Attributable profits are those the permanent establishment would earn as a distinct and separate enterprise dealing independently under similar conditions. Deductions are allowed for expenses incurred for the permanent establishment's business subject to local tax law limits; mere purchase of goods does not give rise to attributed profits. The same attribution method applies year to year unless justified otherwise, 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=6021