https://www.taxtmi.com/acts?id=44816 Business profits are taxable only in the State of the enterprise unless business is carried on in the other State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Attribution must follow the separate and independent enterprise principle. Deductions are allowed for expenses incurred for the purposes of the permanent establishment, subject to the taxing State's law and limitations, but amounts passed between head office and permanent establishment (other than reimbursement of actual expenses) by way of royalties, fees, commissions, management charges or, except for banking enterprises, interest are not to be allowed as deductions or taken into account. en-us Wed, 16 Oct 2024 15:36:11 +0530 Tue, 22 Oct 2024 13:01:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44816 Business profits are taxable only in the State of the enterprise unless business is carried on in the other State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Attribution must follow the separate and independent enterprise principle. Deductions are allowed for expenses incurred for the purposes of the permanent establishment, subject to the taxing State's law and limitations, but amounts passed between head office and permanent establishment (other than reimbursement of actual expenses) by way of royalties, fees, commissions, management charges or, except for banking enterprises, interest are not to be allowed as deductions or taken into account. Act-Rules DTAA Wed, 16 Oct 2024 15:36:11 +0530 https://www.taxtmi.com/acts?id=44816