https://www.taxtmi.com/acts?id=18942 Business profits are taxable only in the enterprise's resident State unless business is carried on in the other Contracting State through a permanent establishment, in which case only profits attributable to that establishment may be taxed there. Attribution follows the separate enterprise principle, allowing deductions for expenses incurred for the establishment subject to domestic limitations; customary apportionment methods may be used if they align with these principles. Purchases of goods by the establishment do not generate attributed profits, attribution methods should be applied consistently year to year, and other Articles govern separately dealt with income. en-us Mon, 01 Sep 2014 13:01:45 +0530 Mon, 18 Nov 2024 16:07:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=18942 Business profits are taxable only in the enterprise's resident State unless business is carried on in the other Contracting State through a permanent establishment, in which case only profits attributable to that establishment may be taxed there. Attribution follows the separate enterprise principle, allowing deductions for expenses incurred for the establishment subject to domestic limitations; customary apportionment methods may be used if they align with these principles. Purchases of goods by the establishment do not generate attributed profits, attribution methods should be applied consistently year to year, and other Articles govern separately dealt with income. Act-Rules DTAA Mon, 01 Sep 2014 13:01:45 +0530 https://www.taxtmi.com/acts?id=18942