Permanent establishment definition: fixed place and agent activities can create taxable presence under a tax treaty with specific exclusions.

Permanent establishment is a fixed place of business through which an enterprise's business is carried on; specific places and activities are enumerated, time and activity thresholds determine creation of a permanent establishment, exclusions apply for preparatory or auxiliary functions and certain storage or purchasing activities, and agency rules attribute a permanent establishment where agents habitually conclude contracts, maintain delivery stock with contributing sales activities, or secure orders, while independent agents acting in the ordinary course do not create a permanent establishment absent exclusive devotion or non arm's length dealings.

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