Permanent Establishment definition expanded to include assembly and installation, and air transport provisions made retroactively applicable. The Protocol clarifies that for the purposes of the double taxation agreement the term 'assembly project' includes installation of equipment and that clauses governing use of facilities and maintenance of stock apply where storage or display also serves delivery of spare parts from local stock during the relevant contract period. It further provides that air transport provisions apply from an earlier date and allow for refund of tax paid on application within a prescribed period, and records that both Parties have completed the formalities for entry into force and ratification.
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 definition expanded to include assembly and installation, and air transport provisions made retroactively applicable.
The Protocol clarifies that for the purposes of the double taxation agreement the term "assembly project" includes installation of equipment and that clauses governing use of facilities and maintenance of stock apply where storage or display also serves delivery of spare parts from local stock during the relevant contract period. It further provides that air transport provisions apply from an earlier date and allow for refund of tax paid on application within a prescribed period, and records that both Parties have completed the formalities for entry into force and ratification.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
