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The India UAE treaty sets more than 9 months within any twelve month period for services furnished through

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The catch is the clock the number of months that actually creates a PE is usually fixed by the double tax treaty

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Summary A PE arises only if an enterprise maintains a physical presence in the host country for a period exceeding the treaty

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The tax treaty between States A and C has a 12 month time threshold for a construction site PE but that between

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Since the employees are rendering such services in KSA for only 4 months the Egyptian company is not deemed to have a PE in

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A Construction and Installation Permanent Establishment arises when a building site installation or supervisory

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Yes if the project runs beyond the PE threshold in the applicable treaty typically 6 12 months Once the threshold is

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It follows that in order to be qualified as a PE a building site or construction or installation project must exist for a

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The OECD Model Treaty Article 5 includes specific provisions in paragraph 3 that a building site or construction or