https://www.taxtmi.com/acts?id=6182 The Convention establishes a termination mechanism allowing either Contracting State to terminate by diplomatic notice after a ten-year period, causing cessation of treaty effects for defined taxes from specified taxable periods following notice. It clarifies that construction and building-site duration tests exclude time on unrelated sites, apply separately to unconnected sites or groups of connected sites, and treat a commercially and geographically coherent building site as a single site; that permanent establishment activity is assessed on all relevant circumstances notwithstanding contracting through head office; and that interest from direct operation receipts of international aircraft is included in profits while reinvested interest is excluded. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 26 Dec 2024 12:13:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6182 The Convention establishes a termination mechanism allowing either Contracting State to terminate by diplomatic notice after a ten-year period, causing cessation of treaty effects for defined taxes from specified taxable periods following notice. It clarifies that construction and building-site duration tests exclude time on unrelated sites, apply separately to unconnected sites or groups of connected sites, and treat a commercially and geographically coherent building site as a single site; that permanent establishment activity is assessed on all relevant circumstances notwithstanding contracting through head office; and that interest from direct operation receipts of international aircraft is included in profits while reinvested interest is excluded. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6182