Permanent establishment rules: fixed place, exclusions, and anti avoidance treating dependent agents and commissionaires as creating PE.

Article 5 treats a permanent establishment as a fixed place of business (e.g., management, branch, office, factory, warehouse, sales premises, extraction or exploration installations) and provides that construction sites constitute a permanent establishment only if they exceed a temporal threshold. It lists exclusions for purely preparatory or auxiliary activities (storage, display, purchasing, information, advertising, research, or combined such activities), subject to an anti-fragmentation rule where related enterprises or complementary functions convert excluded activities into a permanent establishment. Agency rules and MLI modifications address dependent agents, commissionaire arrangements and persons acting almost exclusively for related enterprises.

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