https://www.taxtmi.com/acts?id=45346 Profits are taxable in the State of residence unless a permanent establishment exists in the other State, in which case only profits attributable to that permanent establishment, related sales, or similar activities may be taxed there. Attribution follows the separate enterprise principle. Deductions are allowed for expenses incurred for the permanent establishment, subject to local tax law, but not for amounts (other than reimbursements of actual expenses) charged between the permanent establishment and head office for royalties, management charges, commissions or, except for banks, interest. No profits arise from mere purchases, and the attribution method should be applied year by year. en-us Fri, 18 Oct 2024 12:17:11 +0530 Fri, 18 Oct 2024 12:17:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45346 Profits are taxable in the State of residence unless a permanent establishment exists in the other State, in which case only profits attributable to that permanent establishment, related sales, or similar activities may be taxed there. Attribution follows the separate enterprise principle. Deductions are allowed for expenses incurred for the permanent establishment, subject to local tax law, but not for amounts (other than reimbursements of actual expenses) charged between the permanent establishment and head office for royalties, management charges, commissions or, except for banks, interest. No profits arise from mere purchases, and the attribution method should be applied year by year. Act-Rules DTAA Fri, 18 Oct 2024 12:17:11 +0530 https://www.taxtmi.com/acts?id=45346