Artificial avoidance of permanent establishment status: notification of Option A and identification of treaties' specific activity exemptions. India elects to apply Option A under Article 13(1) of the Convention to prevent artificial avoidance of permanent establishment status via specific activity exemptions, and notifies that numerous existing bilateral tax treaties contain provisions described in Article 13(5)(a), identifying for each listed contracting jurisdiction the article and paragraph where the specific activity exemption or comparable provision appears.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Artificial avoidance of permanent establishment status: notification of Option A and identification of treaties' specific activity exemptions.
India elects to apply Option A under Article 13(1) of the Convention to prevent artificial avoidance of permanent establishment status via specific activity exemptions, and notifies that numerous existing bilateral tax treaties contain provisions described in Article 13(5)(a), identifying for each listed contracting jurisdiction the article and paragraph where the specific activity exemption or comparable provision appears.
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