Permanent establishment definition clarifies fixed place and dependent agent criteria determining taxable presence under the treaty.

Permanent establishment is a fixed place of business through which an enterprise's business wholly or partly is carried on, encompassing management offices, branches, production and extraction sites, sales outlets, and construction or installation projects meeting the treaty's duration and transactional thresholds. Excluded are facilities used solely for storage, display, purchasing, information collection, or scientific research. A dependent agent may create a permanent establishment by habitually concluding contracts, maintaining stock for delivery, or securing orders almost exclusively for the enterprise, whereas independent agents acting in the ordinary course and mere corporate control do not by themselves create a permanent establishment.

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