https://www.taxtmi.com/acts?id=6313 Profits of an enterprise are taxable only in its resident State unless it carries on business in the other State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Where sales or services mirror those of the permanent establishment, profits may be attributed to it unless shown otherwise. Attributable profits should reflect what the establishment would earn as a separate enterprise; estimation is allowed if accurate determination is impracticable. Deductions for expenses incurred for the establishment's business are permitted subject to domestic disallowances, and purchases for export to the head office do not, by themselves, create attributable profits. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 25 Nov 2024 12:14:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6313 Profits of an enterprise are taxable only in its resident State unless it carries on business in the other State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Where sales or services mirror those of the permanent establishment, profits may be attributed to it unless shown otherwise. Attributable profits should reflect what the establishment would earn as a separate enterprise; estimation is allowed if accurate determination is impracticable. Deductions for expenses incurred for the establishment's business are permitted subject to domestic disallowances, and purchases for export to the head office do not, by themselves, create attributable profits. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6313