Permanent establishment defined as fixed place of business; agency, services and construction activities can create taxable presence.

Article 5 defines permanent establishment as a fixed place of business through which an enterprise's business is wholly or partly carried on, listing specific examples and treating construction sites and service-provision through personnel as PEs where activities exceed continuity thresholds. It excludes preparatory or auxiliary activities such as storage, display, delivery, purchasing and information collection. Agency rules deem a PE where a dependent person habitually concludes contracts, maintains stock for delivery, or secures orders, while independent agents acting in the ordinary course of business are excluded. Insurance enterprises (except reinsurance) collecting premiums or insuring risks through non-independent agents are deemed to have a PE.

---

---

---