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April 12, 2018

Glenn was the first American to orbit Earth, piloting Friendship 7 around the planet three times in 1962. Senator at age 77, also became the oldest person in space by orbiting Earth with six astronauts aboard shuttle Discovery in 1998. (AP Photo/Jay LaPrete).

UN Approach The concept of Service PE exists in Article 5 of UN MC. UN MC, which favors source based taxation, though does not specifically use the expression “Service PE”, but it Article 5(3) (b), which deals with the concept of Service PE reads as under; “The furnishing of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within a Contracting State for a period or periods aggregating more than six months within any twelve month period” Developing and emerging economies, which are predominantly capital importing nations, generally try and negotiate Service PE clause in bilateral treaties, so as to tax profits of foreign enterprises operating within their territories, even in circumstances where no Fixed or Agency PE exists. Indian Tax Treaties India tax treaties are a combination of both OECD and UN MC.

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Posted in News by Dr. Mohamed Nuri Hamdoun