Permanent establishment creates tax nexus where fixed place or dependent agent conducts core business activities, creating taxable presence.

Article 5 defines a permanent establishment as a fixed place of business (including management, branch, office, factory, workshop, extraction sites, sales outlets, warehouses for others, farms) and treats construction sites as permanent establishments only if they exceed twelve months. It excludes solely preparatory or auxiliary activities (storage, display, delivery, purchasing, information collection, holding stocks for processing). Dependent agent criteria create a permanent establishment where a person habitually concludes contracts, maintains stocks for delivery, or secures orders for the enterprise, while independent agents acting in the ordinary course do not.

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