Permanent establishment definitions clarify fixed place, service and agency thresholds that create tax presence under treaty rules.

Article 5 defines permanent establishment as a fixed place of business and lists examples (management, branch, office, factory, workshop, sales outlet, agricultural sites, mines, warehouses). Building sites, construction/installation projects and service provisions by personnel constitute a permanent establishment when activities aggregate more than 183 days in twelve months. Exclusions cover solely preparatory or auxiliary functions (storage, display, stock for processing, purchasing, information collection). Dependent agents with authority to conclude contracts, maintain delivery stock, or secure orders create a permanent establishment, whereas independent agents acting in the ordinary course do not. Insurance activities via non-independent agents also create a permanent establishment. Control between related resident companies alone does not create one.

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