https://www.taxtmi.com/acts?id=44941 An enterprise is taxable in its State of residence except where it carries on business through a permanent establishment in the other State, in which case only profits directly or indirectly attributable to that permanent establishment may be taxed there. Attribution must follow the arm's length principle, treating the permanent establishment as a distinct and separate enterprise; deductible expenses incurred for the purposes of the permanent establishment are allowed. Customary apportionment methods remain permissible if consistent with the Article, purchases for the enterprise do not create attributable profits, and the chosen method should be used consistently year to year. en-us Wed, 16 Oct 2024 17:18:24 +0530 Tue, 22 Oct 2024 14:50:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44941 An enterprise is taxable in its State of residence except where it carries on business through a permanent establishment in the other State, in which case only profits directly or indirectly attributable to that permanent establishment may be taxed there. Attribution must follow the arm's length principle, treating the permanent establishment as a distinct and separate enterprise; deductible expenses incurred for the purposes of the permanent establishment are allowed. Customary apportionment methods remain permissible if consistent with the Article, purchases for the enterprise do not create attributable profits, and the chosen method should be used consistently year to year. Act-Rules DTAA Wed, 16 Oct 2024 17:18:24 +0530 https://www.taxtmi.com/acts?id=44941