https://www.taxtmi.com/acts?id=14919 Profits are taxable in the enterprise's State of residence unless business is carried on through a permanent establishment in the other Contracting State, in which case only profits attributable to that permanent establishment may be taxed there. Attribution must reflect the profits a distinct and separate enterprise would earn under similar conditions, allowing deductions for expenses incurred for the permanent establishment subject to domestic limitations, while disallowing non reimbursed intra enterprise royalties, fees, commissions, management charges and, except for banks, interest; customary apportionment methods are permitted if consistent and methods remain consistent year to year unless changed for good cause. en-us Tue, 30 Aug 2011 11:38:47 +0530 Mon, 18 Nov 2024 18:14:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=14919 Profits are taxable in the enterprise's State of residence unless business is carried on through a permanent establishment in the other Contracting State, in which case only profits attributable to that permanent establishment may be taxed there. Attribution must reflect the profits a distinct and separate enterprise would earn under similar conditions, allowing deductions for expenses incurred for the permanent establishment subject to domestic limitations, while disallowing non reimbursed intra enterprise royalties, fees, commissions, management charges and, except for banks, interest; customary apportionment methods are permitted if consistent and methods remain consistent year to year unless changed for good cause. Act-Rules DTAA Tue, 30 Aug 2011 11:38:47 +0530 https://www.taxtmi.com/acts?id=14919