Article 7(2) - India USA Treaty - Profits attributable to a PE - CA Final International Taxation

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Article 7(2) - India USA Treaty - Profits attributable to a PE - CA Final International Taxation - CA Arinjay Jain

ARTICLE 7(2) – INDIA USA TREATY

Subject to the provisions of paragraph 3,
where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent
establishment situated therein,
there shall in each Contracting State be attributed to that permanent establishment
the profits which it might be expected to make if it were a
distinct and independent enterprise
engaged in the same or similar activities
under the same or similar conditions and
dealing wholly at arm's length
with the enterprise of which it is a permanent establishment and other enterprises controlling, controlled by or subject to
the same common control as that enterprise.
In any case where the correct amount of profits attributable to a permanent establishment is incapable of determination or the determination thereof presents exceptional difficulties, the profits attributable to the permanent establishment may be estimated on a reasonable basis. The estimate adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article.

BASIS OF ALLOCATING PROFITS
ca final international taxationca final international taxation paper 6cca arinjay jain

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