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of <h1>Article 14 Targets Contract Splitting to Avoid Permanent Establishment in Tax Treaties; Aggregates Activities Over 30 Days</h1> Article 14 of the Convention to Implement Tax Treaty Measures addresses the splitting-up of contracts to prevent the avoidance of permanent establishment status under Double Tax Avoidance Agreements (DTAA). It specifies that activities conducted by enterprises in a contracting jurisdiction, particularly those related to construction or consultancy, are aggregated if they exceed 30 days, potentially establishing a permanent establishment. The provision applies even if contracts are divided to circumvent time thresholds. Parties can reserve the right to exclude this article from their agreements, particularly regarding natural resource exploration. Notifications to the Depositary are required if the article applies to existing agreements.
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