https://www.taxtmi.com/acts?id=8084 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 determined as if the permanent establishment were a distinct and separate enterprise engaged in similar activities under similar conditions, allowing deductible expenses incurred for the permanent establishment but disallowing certain payments to the head office; customary apportionment and estimation by tax authorities are permitted consistent with the Article's principles. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 25 Nov 2024 14:25:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=8084 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 determined as if the permanent establishment were a distinct and separate enterprise engaged in similar activities under similar conditions, allowing deductible expenses incurred for the permanent establishment but disallowing certain payments to the head office; customary apportionment and estimation by tax authorities are permitted consistent with the Article's principles. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=8084