https://www.taxtmi.com/acts?id=45541 The treaty confines taxation of an enterprise's profits to its State of residence unless the enterprise operates in the other State through a permanent establishment, in which case only profits attributable to that permanent establishment, related local sales, or similar local activities may be taxed there. Profits are attributed by treating the permanent establishment as a distinct and separate enterprise dealing independently; estimates are permitted where determination is difficult. Deductions are allowed for expenses incurred for the establishment's business subject to local tax law, but not for non reimbursed charges between head office and establishment such as royalties, commissions, management charges or, except for banks, interest. en-us Fri, 18 Oct 2024 16:26:06 +0530 Fri, 18 Oct 2024 16:26:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45541 The treaty confines taxation of an enterprise's profits to its State of residence unless the enterprise operates in the other State through a permanent establishment, in which case only profits attributable to that permanent establishment, related local sales, or similar local activities may be taxed there. Profits are attributed by treating the permanent establishment as a distinct and separate enterprise dealing independently; estimates are permitted where determination is difficult. Deductions are allowed for expenses incurred for the establishment's business subject to local tax law, but not for non reimbursed charges between head office and establishment such as royalties, commissions, management charges or, except for banks, interest. Act-Rules DTAA Fri, 18 Oct 2024 16:26:06 +0530 https://www.taxtmi.com/acts?id=45541