Permanent establishment rules allow future insurance-deeming provisions after consultation, affecting tax treatment under the India-Lithuania treaty. Protocol to the India-Lithuania tax treaty clarifies that Lithuania then had no special DTA rule deeming an insurance enterprise to have a permanent establishment via a dependent agent, but, if such a rule is later adopted in Lithuania's DTAs, the competent authorities will consult on applying it to this Agreement. It confirms taxation of income from enjoyment of company-held immovable property at the situs, mandates minimum head office expense deductions at least equal to Indian law at entry into force, disallows certain PE-to-head-office payments (except reimbursements and certain banking interest), and treats container activities and directly connected interest as profits from international shipping/aircraft operations.