Permanent establishment rules tightened, lowering thresholds and expanding service PE, altering profit attribution and information exchange.

The Protocol amends the India-Kazakhstan tax convention to require profit attribution to permanent establishments on remuneration attributable to their actual activities rather than total contract value, tightens PE thresholds including a new service-PE rule and associated-enterprise linkage, broadens definitions of Kazakhstan and resident, adds a corresponding adjustment for associated enterprises, revises sourcing for interest and royalties, introduces a Limitation of Benefits rule, and expands exchange-of-information and mutual assistance in collection provisions.

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