https://www.taxtmi.com/acts?id=15057 Profits of an enterprise are taxable only in its State of residence 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. Profits attributable are determined as if the permanent establishment were a separate enterprise operating under similar conditions, allowing deductions for expenses incurred for the permanent establishment in accordance with that State's tax laws. Customary apportionment of total profits may be used if consistent with the Article, purchases of goods alone do not create attributable profits, and the method of attribution should be applied year by year unless reasons justify change. en-us Tue, 30 Aug 2011 14:23:15 +0530 Thu, 28 Nov 2024 12:41:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=15057 Profits of an enterprise are taxable only in its State of residence 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. Profits attributable are determined as if the permanent establishment were a separate enterprise operating under similar conditions, allowing deductions for expenses incurred for the permanent establishment in accordance with that State's tax laws. Customary apportionment of total profits may be used if consistent with the Article, purchases of goods alone do not create attributable profits, and the method of attribution should be applied year by year unless reasons justify change. Act-Rules DTAA Tue, 30 Aug 2011 14:23:15 +0530 https://www.taxtmi.com/acts?id=15057