https://www.taxtmi.com/acts?id=16855 Profits of an enterprise are taxable only where the enterprise is resident unless it 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; attribution follows the separate and independent enterprise principle, allows deductions for expenses incurred for the permanent establishment subject to host State law, disallows certain payments between permanent establishment and head office (except specified banking interest allowances), permits customary apportionment consistent with the Article, forbids attribution solely for purchases, and requires consistent application year to year. en-us Fri, 03 Aug 2012 18:32:20 +0530 Mon, 02 Sep 2024 14:09:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=16855 Profits of an enterprise are taxable only where the enterprise is resident unless it 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; attribution follows the separate and independent enterprise principle, allows deductions for expenses incurred for the permanent establishment subject to host State law, disallows certain payments between permanent establishment and head office (except specified banking interest allowances), permits customary apportionment consistent with the Article, forbids attribution solely for purchases, and requires consistent application year to year. Act-Rules DTAA Fri, 03 Aug 2012 18:32:20 +0530 https://www.taxtmi.com/acts?id=16855