https://www.taxtmi.com/acts?id=45479 Profits are taxable only in the residence State unless business is carried on in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Attribution follows the separate enterprise principle, assigning profits the permanent establishment would earn dealing independently. Deductions include expenses incurred for the permanent establishment's business, subject to local tax law limits. Customary apportionment may be used if consistent with these principles; mere purchasing of goods does not generate attributable profits and methods should remain consistent year to year. en-us Fri, 18 Oct 2024 15:01:52 +0530 Fri, 18 Oct 2024 15:01:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45479 Profits are taxable only in the residence State unless business is carried on in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment may be taxed there. Attribution follows the separate enterprise principle, assigning profits the permanent establishment would earn dealing independently. Deductions include expenses incurred for the permanent establishment's business, subject to local tax law limits. Customary apportionment may be used if consistent with these principles; mere purchasing of goods does not generate attributable profits and methods should remain consistent year to year. Act-Rules DTAA Fri, 18 Oct 2024 15:01:52 +0530 https://www.taxtmi.com/acts?id=45479