https://www.taxtmi.com/acts?id=19343 Profits are taxable in the resident State unless an enterprise 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 must treat the permanent establishment as a distinct and separate enterprise on an arm's length basis; deductions for expenses incurred for the permanent establishment are allowed subject to local tax law limits. Purchases alone do not give rise to attributed profits. The attribution method should be applied consistently year to year, and other Articles addressing specific income prevail over this Article. en-us Fri, 20 Mar 2015 16:14:55 +0530 Wed, 13 Nov 2024 16:34:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=19343 Profits are taxable in the resident State unless an enterprise 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 must treat the permanent establishment as a distinct and separate enterprise on an arm's length basis; deductions for expenses incurred for the permanent establishment are allowed subject to local tax law limits. Purchases alone do not give rise to attributed profits. The attribution method should be applied consistently year to year, and other Articles addressing specific income prevail over this Article. Act-Rules DTAA Fri, 20 Mar 2015 16:14:55 +0530 https://www.taxtmi.com/acts?id=19343