Permanent establishment-fixed place or dependent agent activity can create tax presence when substantive business functions are carried out.

Permanent establishment is a fixed place of business through which an enterprise carries on business, including management offices, branches, factories, sales premises, warehouses for storage, extraction sites and construction projects that meet duration or charge-based thresholds. Service activities furnished through personnel create a permanent establishment when they exceed specified time thresholds, and preparatory or auxiliary activities are excluded unless combined with other business places or rendered non auxiliary by complementary activities of the same or closely related enterprises under the MLI anti avoidance modification. Agents habitually negotiating contracts, maintaining delivery stocks, or securing orders may create a permanent establishment, whereas independent agents and mere corporate control do not automatically do so.

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