https://www.taxtmi.com/acts?id=37638 Profits are taxable only in the State of residence unless the 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 follows the separate enterprise principle, allowing deductions for expenses incurred for the permanent establishment subject to host State tax law, while disallowing non reimbursement payments between head office and permanent establishment for royalties, management charges, commissions and, except for banks, interest; customary apportionment and consistency rules also apply. en-us Thu, 19 Sep 2019 12:12:48 +0530 Tue, 26 Nov 2024 17:41:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=37638 Profits are taxable only in the State of residence unless the 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 follows the separate enterprise principle, allowing deductions for expenses incurred for the permanent establishment subject to host State tax law, while disallowing non reimbursement payments between head office and permanent establishment for royalties, management charges, commissions and, except for banks, interest; customary apportionment and consistency rules also apply. Act-Rules DTAA Thu, 19 Sep 2019 12:12:48 +0530 https://www.taxtmi.com/acts?id=37638