News and Press Release - Dated:- 13-7-2018 - F. No. 370142/11/2018-TPL Government of India Ministry of Finance Department of Revenue Central Board of Direct Taxes **** New Delhi, dated the 13th of July, 2018 Subject: reg. As per the allocation of taxing rules under Article 7 of Double Taxation Avoidance Agreements, business profit of an enterprise is taxable in the country in which the taxpayer is a resident. However, if an enterprise carries on its business in another country through a 'Permanent Establishment' situated therein, such other country may also tax the business profits attributable to the 'Permanent Establishment'. For this purpose, Permanent Establishment means a fixed place of business through which the business of an enterprise is wholly or partly carried out provided that the business activities are not of preparatory or auxiliary in nature and such business activities are not carried out by a dependent agent. 2. For a long time, nexus based on physic

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