[ compiled answer ]
law as at 14 Aug 2026 · settled
What is the construction PE threshold under the India–US treaty?
The compiled answer
More than 120 days in any twelve-month period — Article 5(2)(k), India–US DTAA. Not the OECD Model's twelve months and not 183 days. Connected sites, projects and supervisory activities are AGGREGATED ("together with other such sites, projects or activities").
compiled value: 120
Pinpoint
Article 5(2)(k), India–US DTAA (1990)
String-verified quote
“continue for a period of more than 120 days in any twelve month period”
source: provision:IN-US.ART5 — verified at load; a quote that stops matching its source is a compile error
Computed by a deterministic engine over compiled law — no generative model in the evaluation path. JSON twin: /t/construction_pe_days_india_usa.json · Ask with YOUR facts: GET /compute?lookup=… · MCP: POST https://lrlabs.ai/mcp (lookup_compiled_rule)