https://www.taxtmi.com/acts?id=44716 The protocol modifies permanent establishment treatment for site, project or similar activities spanning two taxable years: if, under the specified short term PE rules, the use, site, project or activity aggregates to less than thirty days in one taxable year, no PE is deemed to exist in that year; a PE will exist in the other taxable year and the enterprise is taxable in that other Contracting State only on income arising during that other taxable year. en-us Wed, 16 Oct 2024 13:19:57 +0530 Wed, 23 Oct 2024 16:22:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44716 The protocol modifies permanent establishment treatment for site, project or similar activities spanning two taxable years: if, under the specified short term PE rules, the use, site, project or activity aggregates to less than thirty days in one taxable year, no PE is deemed to exist in that year; a PE will exist in the other taxable year and the enterprise is taxable in that other Contracting State only on income arising during that other taxable year. Act-Rules DTAA Wed, 16 Oct 2024 13:19:57 +0530 https://www.taxtmi.com/acts?id=44716