Permanent establishment rules expanded to include shorter thresholds and service provisions, altering cross-border tax attribution. The Government of India notifies an amending Protocol to the India-Kazakhstan tax Convention implementing revisions: expanded taxes covered and clarified definitions; updated resident criteria including place of registration; tightened permanent establishment rules with a services-based PE and reduced duration thresholds; allowance for profit apportionment for permanent establishments; strengthened associated enterprises adjustments; royalties deemed to arise where the payer is resident; expanded exchange of information and added mutual assistance in collection; and a Limitation of Benefits denying treaty access where benefits are a main purpose or the claimant is not beneficial owner.