https://www.taxtmi.com/acts?id=15118 Profits of an enterprise are taxable only in its State unless it carries on business in the other Contracting State through a permanent establishment; then only profits attributable to that permanent establishment may be taxed there. Attribution treats the permanent establishment as a distinct and separate enterprise under similar conditions; allowable deductions include expenses incurred for its business per the tax law of the State where it is situated, while non deductible or non recognised items include intra enterprise royalties, commissions, management charges and, except for banks, interest on internal loans. en-us Tue, 30 Aug 2011 15:24:07 +0530 Fri, 22 Nov 2024 14:34:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=15118 Profits of an enterprise are taxable only in its State unless it carries on business in the other Contracting State through a permanent establishment; then only profits attributable to that permanent establishment may be taxed there. Attribution treats the permanent establishment as a distinct and separate enterprise under similar conditions; allowable deductions include expenses incurred for its business per the tax law of the State where it is situated, while non deductible or non recognised items include intra enterprise royalties, commissions, management charges and, except for banks, interest on internal loans. Act-Rules DTAA Tue, 30 Aug 2011 15:24:07 +0530 https://www.taxtmi.com/acts?id=15118