Permanent establishment rules determine when fixed places, prolonged projects or dependent agents create tax presence in another state.

The Article defines permanent establishment as a fixed place of business including listed examples, treats prolonged construction or extraction-related activities and provision of plant or services for mineral oil prospecting as creating a permanent establishment, and sets out exclusions for purely preparatory or auxiliary activities and certain stockholding arrangements. It attributes a permanent establishment to enterprises whose non-independent agents habitually conclude contracts, maintain delivery stock, or secure orders in the State, and treats insurance enterprises collecting premiums or insuring risks in the other State as creating a permanent establishment except for reinsurance when carried out through an independent agent.

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