https://www.taxtmi.com/acts?id=44878 Profits of an enterprise are taxable only in its State of residence unless business is carried on through a permanent establishment in the other State; where a permanent establishment exists, only profits attributable to it may be taxed there. Attribution follows the separate enterprise principle, allowing deductions for expenses incurred for the permanent establishment as if it were a distinct enterprise, subject to local rules for executive and administrative expenses and disallowing attribution based solely on purchases. The same method for determining profits should be used year to year, and items governed by other Articles remain unaffected. en-us Wed, 16 Oct 2024 16:28:53 +0530 Tue, 22 Oct 2024 15:29:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44878 Profits of an enterprise are taxable only in its State of residence unless business is carried on through a permanent establishment in the other State; where a permanent establishment exists, only profits attributable to it may be taxed there. Attribution follows the separate enterprise principle, allowing deductions for expenses incurred for the permanent establishment as if it were a distinct enterprise, subject to local rules for executive and administrative expenses and disallowing attribution based solely on purchases. The same method for determining profits should be used year to year, and items governed by other Articles remain unaffected. Act-Rules DTAA Wed, 16 Oct 2024 16:28:53 +0530 https://www.taxtmi.com/acts?id=44878