https://www.taxtmi.com/acts?id=6158 Article 7 allocates taxing rights over business profits to the State of the enterprise unless profits are attributable to a permanent establishment in the other State; such profits are determined by treating the permanent establishment as a distinct and separate enterprise or by proportionate attribution where it contributes to contracts. Deductions are allowed for expenses incurred for the permanent establishment, including executive and administrative costs, subject to domestic limitations, while specified payments between head office and permanent establishment (royalties, fees, commissions, management charges, and generally interest) are excluded from deduction unless reimbursements of actual expenses or excepted for banking enterprises. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 08 Oct 2024 10:04:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6158 Article 7 allocates taxing rights over business profits to the State of the enterprise unless profits are attributable to a permanent establishment in the other State; such profits are determined by treating the permanent establishment as a distinct and separate enterprise or by proportionate attribution where it contributes to contracts. Deductions are allowed for expenses incurred for the permanent establishment, including executive and administrative costs, subject to domestic limitations, while specified payments between head office and permanent establishment (royalties, fees, commissions, management charges, and generally interest) are excluded from deduction unless reimbursements of actual expenses or excepted for banking enterprises. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6158