Permanent establishment attribution and principal purpose test govern India-Sri Lanka treaty benefits and restrict treaty-shopping arrangements.

India-Sri Lanka treaty rules confine permanent-establishment profits to receipts and contractual activities actually attributable to, or effectively carried out by, the permanent establishment. More beneficial domestic-law provisions prevail for a resident of the other Contracting State. The amending protocol introduces a principal purpose test, allowing denial of treaty benefits where obtaining the benefit was one principal purpose of an arrangement or transaction, unless the benefit accords with the object and purpose of the relevant treaty provisions. It enters into force after reciprocal diplomatic notification and applies prospectively to specified taxable periods.

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