Permanent establishment rules define when fixed places, dependent agents, or service projects create taxable presence under a tax treaty. The Article defines permanent establishment as a fixed place of business including specific examples, treats construction projects and the furnishing of services as permanent establishments only when they exceed stated temporal thresholds, excludes preparatory or auxiliary activities (such as storage, display, purchasing, processing arrangements and similar combinations), and provides agency and insurance rules whereby dependent agents, stock-holding activities for delivery, or habitually securing orders can create a permanent establishment while independent agents and mere corporate control 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 rules define when fixed places, dependent agents, or service projects create taxable presence under a tax treaty.
The Article defines permanent establishment as a fixed place of business including specific examples, treats construction projects and the furnishing of services as permanent establishments only when they exceed stated temporal thresholds, excludes preparatory or auxiliary activities (such as storage, display, purchasing, processing arrangements and similar combinations), and provides agency and insurance rules whereby dependent agents, stock-holding activities for delivery, or habitually securing orders can create a permanent establishment while independent agents and mere corporate control do not.
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