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.
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.
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.
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