Permanent establishment defines tax presence when business is carried on through a fixed place or dependent agent creating nexus. Permanent establishment is a fixed place of business through which an enterprise's business is carried on, including management, branches, offices, factories, and sites for extraction or agriculture; construction, assembly or installation projects become permanent establishments when continuing beyond twelve months. Exclusions cover places used solely for storage, display, occasional delivery, purchasing, information collection, advertising, supply of information, scientific research or other preparatory or auxiliary activities. A dependent person with authority to conclude contracts or maintaining stocks for regular delivery, and insurance activities through non-independent agents, create a permanent establishment, whereas independent agents acting in their ordinary course do not.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Permanent establishment defines tax presence when business is carried on through a fixed place or dependent agent creating nexus.
Permanent establishment is a fixed place of business through which an enterprise's business is carried on, including management, branches, offices, factories, and sites for extraction or agriculture; construction, assembly or installation projects become permanent establishments when continuing beyond twelve months. Exclusions cover places used solely for storage, display, occasional delivery, purchasing, information collection, advertising, supply of information, scientific research or other preparatory or auxiliary activities. A dependent person with authority to conclude contracts or maintaining stocks for regular delivery, and insurance activities through non-independent agents, create a permanent establishment, whereas independent agents acting in their ordinary course do not.
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