https://www.taxtmi.com/acts?id=45508 Article 5 defines Permanent Establishment as a fixed place of business and enumerates specific examples, including construction sites which, if activities continue beyond the treaty threshold, constitute a permanent establishment. The MLI splits-up rule aggregates fragmented periods and closely related enterprises' activities to prevent avoidance. Preparatory or auxiliary activity exemptions are set out but the MLI excludes the exemption where combined or complementary activities by the same or a closely related enterprise are not preparatory or auxiliary. Agency and independent-agent tests determine permanent-establishment attribution, and close-relationship is defined by control or substantial beneficial ownership. en-us Fri, 18 Oct 2024 15:26:14 +0530 Tue, 22 Oct 2024 18:10:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45508 Article 5 defines Permanent Establishment as a fixed place of business and enumerates specific examples, including construction sites which, if activities continue beyond the treaty threshold, constitute a permanent establishment. The MLI splits-up rule aggregates fragmented periods and closely related enterprises' activities to prevent avoidance. Preparatory or auxiliary activity exemptions are set out but the MLI excludes the exemption where combined or complementary activities by the same or a closely related enterprise are not preparatory or auxiliary. Agency and independent-agent tests determine permanent-establishment attribution, and close-relationship is defined by control or substantial beneficial ownership. Act-Rules DTAA Fri, 18 Oct 2024 15:26:14 +0530 https://www.taxtmi.com/acts?id=45508