TMI BlogBusiness profitsX X X X Extracts X X X X X X X X Extracts X X X X ..... enterprise may be taxed in the other Contracting State, but only so much of them as is attributable to that permanent establishment. ] The provisions of this paragraph shall, however, not apply if the enterprise proves that the above activities could not have been undertaken by the permanent establishment or have no relation with the permanent establishment. 2. Subject to the provisions ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... m applying those provisions of its law, provided that the result is in accordance with the principles contained in this Article. 4. In determining the profits of a permanent establishment, there shall be allowed as deduction expenses which are incurred for the purposes of the business of the permanent establishment, including executive and general administrative expenses so incurred, whether in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1. Substituted vide NOTIFICATION NO. 54/2019 dated 17-07-2019 before it was read as 1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting State unless the enterprise carries business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the e ..... X X X X Extracts X X X X X X X X Extracts X X X X
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