Permanent establishment rules for insurance enterprises clarified: Estonia will notify India if deeming clauses are adopted and consult on inclusion.

The Protocol records that Estonia's existing tax treaties at signing do not include a deeming rule treating an insurance enterprise as having a permanent establishment merely by collecting premiums or insuring risks otherwise than through an agent of independent status; if Estonia later includes such a provision in any treaty it shall notify India and, after consultations between competent authorities, that provision may be considered for this Agreement. It also provides that income and gains from alienation of immovable property referred to in Article 6(2) and situated in a Contracting State may be taxed in that State in accordance with Article 13.

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