Permanent establishment: fixed place or dependent agent presence can create taxable business presence under tax treaties.

A permanent establishment exists where an enterprise carries on business through a fixed place of business (examples include management offices, branches, factories, extraction sites, warehouses providing storage for others and sales outlets). Exclusions cover facilities used solely for storage, display, delivery, stocks for processing, purchasing or information collection, and fixed places whose activities are preparatory or auxiliary. Dependent agents may create a permanent establishment if they habitually conclude contracts, maintain stocks for delivery, or secure orders substantially for the enterprise; independent agents acting in the ordinary course do not.

---

---

---