Introducing the “In Favour Of” filter in Case Laws.
- ⚖️ Instantly identify judgments decided in favour of the Assessee, Revenue, or Appellant
- 🔍 Narrow down results with higher precision
Try it now in Case Laws →
TaxTMI Login
🚀 New Feature Launched ✕
Just a moment...
Introducing the “In Favour Of” filter in Case Laws.
Try it now in Case Laws →
Press 'Enter' to add multiple search terms. Rules for Better Search
of 
of 
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of of 
All Acts & Rules
of of All Acts & Rules
Note
Bookmark
Share
Don't have an account? Register Here
of <h1>Understanding 'Permanent Establishment' in Nepal DTAA: Key Criteria and Exceptions for Businesses Operating Abroad</h1> The term 'permanent establishment' in the Double Tax Avoidance Agreement (DTAA) with Nepal refers to a fixed business location where an enterprise's activities are conducted. This includes places like a branch, office, factory, or mine. It also encompasses construction projects lasting over 183 days and service provision exceeding 90 days within a year. However, certain activities, such as storage or preparatory tasks, do not constitute a permanent establishment. Additionally, an enterprise may be deemed to have a permanent establishment if it operates through a dependent agent with authority to conclude contracts or maintains a stock of goods for regular delivery in the other state. Insurance enterprises collecting premiums or insuring risks in the other state are also considered to have a permanent establishment. Independent agents acting in their ordinary course do not create a permanent establishment unless their activities are almost wholly for the enterprise. Control between companies in different states does not automatically establish a permanent establishment.
TaxTMI 
TaxTMI 
