https://www.taxtmi.com/acts?id=45003 Article 7 limits taxation of an enterprise's business profits to its State of residence except insofar as a permanent establishment in the other State earns attributable profits. Profits attributable to a PE are computed on the separate enterprise, arm's length basis. Deductions for expenses incurred for the PE are allowed within the taxing State's law, but amounts (other than reimbursements) charged between PE and head office for royalties, fees, commissions, management charges and, except for banks, interest are disallowed. No profit is attributed merely for purchase activities; attribution methods should be applied consistently year to year, and other Articles govern income treated separately. en-us Wed, 16 Oct 2024 17:50:22 +0530 Tue, 22 Oct 2024 12:10:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45003 Article 7 limits taxation of an enterprise's business profits to its State of residence except insofar as a permanent establishment in the other State earns attributable profits. Profits attributable to a PE are computed on the separate enterprise, arm's length basis. Deductions for expenses incurred for the PE are allowed within the taxing State's law, but amounts (other than reimbursements) charged between PE and head office for royalties, fees, commissions, management charges and, except for banks, interest are disallowed. No profit is attributed merely for purchase activities; attribution methods should be applied consistently year to year, and other Articles govern income treated separately. Act-Rules DTAA Wed, 16 Oct 2024 17:50:22 +0530 https://www.taxtmi.com/acts?id=45003