[ compiled answer ]
law as at 14 Aug 2026 · settled
What is the service PE day threshold under the India–US treaty?
The compiled answer
More than 90 days within any twelve-month period — Article 5(2)(l)(i), India–US DTAA. 183 days is the individual residence / dependent-personal-services test (Articles 4 and 15), a routinely mis-stated threshold. Where the services are for an Article 9(1) related enterprise, limb (l)(ii) applies with NO day floor at all.
compiled value: 90
Pinpoint
Article 5(2)(l)(i), India–US DTAA (1990)
String-verified quote
“aggregating more than 90 days within 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/service_pe_days_india_usa.json · Ask with YOUR facts: GET /compute?lookup=… · MCP: POST https://lrlabs.ai/mcp (lookup_compiled_rule)