https://www.taxtmi.com/acts?id=45195 The treaty defines permanent establishment as a fixed place of business and lists typical forms, while construction and installation projects constitute a PE only when project-duration thresholds are exceeded; the MLI requires aggregation of related periods to counteract contract splitting. Preparatory or auxiliary activities (storage, display, purchasing, information collection, advertising, research, processing by another) are excluded from PE status, but the MLI treats combined or complementary activities by the enterprise or closely related enterprises as a PE where the overall activity is not preparatory or auxiliary. en-us Thu, 17 Oct 2024 16:43:58 +0530 Tue, 22 Oct 2024 16:43:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45195 The treaty defines permanent establishment as a fixed place of business and lists typical forms, while construction and installation projects constitute a PE only when project-duration thresholds are exceeded; the MLI requires aggregation of related periods to counteract contract splitting. Preparatory or auxiliary activities (storage, display, purchasing, information collection, advertising, research, processing by another) are excluded from PE status, but the MLI treats combined or complementary activities by the enterprise or closely related enterprises as a PE where the overall activity is not preparatory or auxiliary. Act-Rules DTAA Thu, 17 Oct 2024 16:43:58 +0530 https://www.taxtmi.com/acts?id=45195