https://www.taxtmi.com/acts?id=43939 The Protocol prescribes that the construction-period time limit in Article 5 begins when construction activity itself begins, excluding preparatory time, and that Article 7 requires profits of a permanent establishment to be determined only on income attributable to the permanent establishment's actual activity in the source State rather than on the enterprise's total contract receipts; head office profits remain taxable only in the resident State. en-us Sat, 24 Aug 2024 12:37:39 +0530 Wed, 11 Dec 2024 17:02:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=43939 The Protocol prescribes that the construction-period time limit in Article 5 begins when construction activity itself begins, excluding preparatory time, and that Article 7 requires profits of a permanent establishment to be determined only on income attributable to the permanent establishment's actual activity in the source State rather than on the enterprise's total contract receipts; head office profits remain taxable only in the resident State. Act-Rules DTAA Sat, 24 Aug 2024 12:37:39 +0530 https://www.taxtmi.com/acts?id=43939