https://www.taxtmi.com/acts?id=6111 Profits are taxable in the State of residence unless an enterprise carries on business through a permanent establishment in the other Contracting State; only profits attributable to that PE may be taxed there. Attribution follows the separate enterprise principle, allowing deductions for expenses incurred for the PE including executive and general administrative costs. Customary apportionment methods may be used if they accord with the article's principles. No profits are attributed to a PE solely for purchasing goods for export to the enterprise, and items covered by other treaty articles remain governed by those articles. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 09 Dec 2024 12:35:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6111 Profits are taxable in the State of residence unless an enterprise carries on business through a permanent establishment in the other Contracting State; only profits attributable to that PE may be taxed there. Attribution follows the separate enterprise principle, allowing deductions for expenses incurred for the PE including executive and general administrative costs. Customary apportionment methods may be used if they accord with the article's principles. No profits are attributed to a PE solely for purchasing goods for export to the enterprise, and items covered by other treaty articles remain governed by those articles. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6111