https://www.taxtmi.com/acts?id=51353 Profits are taxable only in the enterprise's State of residence unless the enterprise carries on business through a permanent establishment in the other State, in which case profits attributable to that permanent establishment may be taxed where it is situated. Attribution uses the separate and independent enterprise standard, considering functions performed, assets used and risks assumed. Where one State adjusts and taxes such profits, the other State should make an appropriate adjustment to eliminate double taxation if it agrees, or otherwise eliminate double taxation by mutual agreement. Items governed by other Articles remain subject to those Articles. en-us Wed, 21 May 2025 15:32:41 +0530 Wed, 21 May 2025 15:32:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=51353 Profits are taxable only in the enterprise's State of residence unless the enterprise carries on business through a permanent establishment in the other State, in which case profits attributable to that permanent establishment may be taxed where it is situated. Attribution uses the separate and independent enterprise standard, considering functions performed, assets used and risks assumed. Where one State adjusts and taxes such profits, the other State should make an appropriate adjustment to eliminate double taxation if it agrees, or otherwise eliminate double taxation by mutual agreement. Items governed by other Articles remain subject to those Articles. Act-Rules DTAA Wed, 21 May 2025 15:32:41 +0530 https://www.taxtmi.com/acts?id=51353