Protocol

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....lishment shall not be determined on the total amount received by the enterprise, but shall be determined only on the basis of that part of the receipts which is attributable to the actual activity of the permanent establishment for such sales or business. Likewise in the case of contracts for survey, supply, services, constructions or installations, when the enterprise has a permanent establishment, the profits of such permanent establishment shall not be determined on the total amount of the contract, but shall be determined only on the basis of that part of the contract which is effectively carried out by the permanent establishment in the Stat, where the permanent establishment is situated. (ii) It is understood that in relation....

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....xation and the prevention of fiscal evasion with respect to taxes on income, signed in India on the 22nd day of January, 2013 (hereinafter referred to as "the Agreement"). Have agreed as follows: ARTICLE 1 The Preamble of the Agreement shall be replaced by the following: "The Government of the Republic of India and the Government of the Democratic Socialist Republic of Sri Lanka, desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and with a view to promoting economic cooperation between the two countries; Intending to eliminate double taxation with respect to the taxes covered by this Agreement without creating opportunities f....