https://www.taxtmi.com/manuals?id=4457 Business profits are taxable in the residence State except where an enterprise carries on business through a permanent establishment (PE) in the other State; profits attributable to the PE may be taxed in that other State. Attribution follows an arm's length principle treating the PE as a separate independent enterprise based on functions, assets and risks. The UN version extends source taxation to sales and similar activities in the source State, allows deduction of actual PE expenses, and disallows non reimbursement charges between PE and head office such as royalties, commissions and most interest. en-us Fri, 02 Feb 2024 17:15:00 +0530 Wed, 14 Feb 2024 17:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/manuals?id=4457 Business profits are taxable in the residence State except where an enterprise carries on business through a permanent establishment (PE) in the other State; profits attributable to the PE may be taxed in that other State. Attribution follows an arm's length principle treating the PE as a separate independent enterprise based on functions, assets and risks. The UN version extends source taxation to sales and similar activities in the source State, allows deduction of actual PE expenses, and disallows non reimbursement charges between PE and head office such as royalties, commissions and most interest. Manuals Income Tax Fri, 02 Feb 2024 17:15:00 +0530 https://www.taxtmi.com/manuals?id=4457