The
protocol amending the agreement between the Government of India and
Australia was signed on the December 16, 2011. However, it has been
notified on September 20, 2013. It is effective from April 2, 2013. Now
Force of attraction' concept is removed from Article 7(1) with insertion
of new Article 7(1). As per the new clause, the business profits of the
enterprise may be taxed in the other State but only so much of them as
are attributable to that PE.
Threshold
limit for establishing Service PE has been increased to 183 days.
Earlier treaty did not provide for any threshold limit for establishing
construction PE. However, the protocol provides for threshold limit of
183 days and 90 days on use of substantial equipments and on activities
in connection with exploration of natural resources.
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