我国政府和印度政府关于对所得避免双重征税和防止偷漏税的协定以下称“协定”，业已生效，并将于1995年1月1日起执行．现就协定有关条文的解释和执行明确如下：一、关于第五条常设机构第五条第二款第（十一）项关于提供劳务构成常设机构的规定，其含义是中、印各方公司、企业 The Agreement between our Government and the Government of India concerning the avoidance of double taxation on income and the prevention of tax evasion is hereinafter referred to as the “Agreement”, which has come into effect and will come into effect on January 1, 1995. The interpretation and implementation of the relevant provisions of the agreement are as follows: 1. Article 5 of Article 5 of the Permanent Establishment Article 5 (2) of the Permanent Establishment provides that the provision of labor services constitutes a permanent establishment on the ground that the Chinese and Indian parties ,enterprise