https://www.taxtmi.com/acts?id=18903 Profits of an enterprise may be taxed in the other Contracting State only to the extent attributable to a permanent establishment, determined as if the establishment were a separate enterprise under the arm's length principle. Deductions are allowed for expenses incurred for the permanent establishment, subject to local tax law limits, but not for non reimbursed charges between head office and establishment such as royalties, fees, commissions, management charges or, except for banks, interest. Apportionment customs may be used if consistent with these principles, and the method must be applied year to year unless changed for good reason. en-us Tue, 12 Aug 2014 13:38:04 +0530 Tue, 26 Nov 2024 17:58:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=18903 Profits of an enterprise may be taxed in the other Contracting State only to the extent attributable to a permanent establishment, determined as if the establishment were a separate enterprise under the arm's length principle. Deductions are allowed for expenses incurred for the permanent establishment, subject to local tax law limits, but not for non reimbursed charges between head office and establishment such as royalties, fees, commissions, management charges or, except for banks, interest. Apportionment customs may be used if consistent with these principles, and the method must be applied year to year unless changed for good reason. Act-Rules DTAA Tue, 12 Aug 2014 13:38:04 +0530 https://www.taxtmi.com/acts?id=18903