Permanent establishment rules revised: services and equipment use can create taxable PE across borders, expanding tax jurisdiction.

The Protocol amends tax treaty rules by expanding the permanent establishment concept to include prolonged service provision through personnel, substantial equipment operation, and resource exploration or exploitation beyond specified durations, and by reaffirming that only profits attributable to such a PE are taxable in the State where it is situated. It adds a Non Discrimination obligation with limited exceptions, broadens Exchange of Information obligations subject to confidentiality and legal limits, and creates mutual Assistance in the Collection of Taxes governed by the requested State's domestic procedures.

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