https://www.taxtmi.com/acts?id=51320 Taxation of business profits rests on the permanent establishment nexus: only profits attributable to a permanent establishment may be taxed in the State where it is situated. Attribution is determined by treating the permanent establishment as a separate and independent enterprise under similar conditions, considering functions, assets and risks. If one State adjusts and taxes such profits, the other State must make an appropriate adjustment to eliminate double taxation, with consultation between competent authorities as necessary. Items covered by other Articles remain governed by those Articles. en-us Wed, 21 May 2025 13:13:20 +0530 Thu, 22 May 2025 12:58:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=51320 Taxation of business profits rests on the permanent establishment nexus: only profits attributable to a permanent establishment may be taxed in the State where it is situated. Attribution is determined by treating the permanent establishment as a separate and independent enterprise under similar conditions, considering functions, assets and risks. If one State adjusts and taxes such profits, the other State must make an appropriate adjustment to eliminate double taxation, with consultation between competent authorities as necessary. Items covered by other Articles remain governed by those Articles. Act-Rules DTAA Wed, 21 May 2025 13:13:20 +0530 https://www.taxtmi.com/acts?id=51320