https://www.taxtmi.com/acts?id=32261 Profits are taxable only in the enterprise's State of residence unless business is carried on in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Such profits are attributed on the separate enterprise basis, with deductions allowed for expenses incurred for the purposes of the permanent establishment subject to the host State's tax law; intercompany charges (other than reimbursements) such as royalties, fees, commissions, management charges and, except for banking, interest are not deductible or recognized in profit attribution. en-us Tue, 15 May 2018 17:28:09 +0530 Mon, 09 Dec 2024 11:23:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=32261 Profits are taxable only in the enterprise's State of residence unless business is carried on in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Such profits are attributed on the separate enterprise basis, with deductions allowed for expenses incurred for the purposes of the permanent establishment subject to the host State's tax law; intercompany charges (other than reimbursements) such as royalties, fees, commissions, management charges and, except for banking, interest are not deductible or recognized in profit attribution. Act-Rules DTAA Tue, 15 May 2018 17:28:09 +0530 https://www.taxtmi.com/acts?id=32261