https://www.taxtmi.com/acts?id=45380 Article 7 provides that business profits are taxable only in the enterprise's State of residence unless the enterprise operates in the other State through a permanent establishment; in that case, only profits attributable to the permanent establishment may be taxed there. Attribution is made as if the permanent establishment were a distinct and separate enterprise under similar conditions, using a consistent method year to year unless a sufficient reason warrants change. Deductions for expenses, including executive and general administrative costs, are allowed subject to the host State's tax law limitations; profits are not attributed merely by purchases of goods, and other Articles govern items dealt with separately. en-us Fri, 18 Oct 2024 12:57:20 +0530 Fri, 18 Oct 2024 12:57:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45380 Article 7 provides that business profits are taxable only in the enterprise's State of residence unless the enterprise operates in the other State through a permanent establishment; in that case, only profits attributable to the permanent establishment may be taxed there. Attribution is made as if the permanent establishment were a distinct and separate enterprise under similar conditions, using a consistent method year to year unless a sufficient reason warrants change. Deductions for expenses, including executive and general administrative costs, are allowed subject to the host State's tax law limitations; profits are not attributed merely by purchases of goods, and other Articles govern items dealt with separately. Act-Rules DTAA Fri, 18 Oct 2024 12:57:20 +0530 https://www.taxtmi.com/acts?id=45380