https://www.taxtmi.com/acts?id=51403 Profits of an enterprise are taxable only in the residence State unless the enterprise carries on business in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment, related sales or similar activities may be taxed there; attribution follows an arm's-length approach, allowing deductions for expenses incurred for the permanent establishment while excluding non-reimbursement inter-company payments such as royalties, management fees, commissions and, except for banks, interest. en-us Thu, 22 May 2025 11:58:33 +0530 Tue, 27 May 2025 12:11:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=51403 Profits of an enterprise are taxable only in the residence State unless the enterprise carries on business in the other Contracting State through a permanent establishment, in which case only profits attributable to that permanent establishment, related sales or similar activities may be taxed there; attribution follows an arm's-length approach, allowing deductions for expenses incurred for the permanent establishment while excluding non-reimbursement inter-company payments such as royalties, management fees, commissions and, except for banks, interest. Act-Rules DTAA Thu, 22 May 2025 11:58:33 +0530 https://www.taxtmi.com/acts?id=51403