Permanent establishment time limit clarified: construction period starts when activity begins; preparatory time excluded; domestic law may prevail if more beneficial.

Clarifies that the six month period for a permanent establishment from construction activities begins when construction activity itself begins and excludes preparatory activity time; and provides that if a Contracting State's domestic tax law is more beneficial to a resident of the other State than the Agreement, that domestic law applies to the extent of the benefit.

---

---

---