Permanent establishment defined as a fixed place of business triggering taxing rights when business activities exceed specified durations.

The Article defines permanent establishment as a fixed place of business through which an enterprise carries on business and lists qualifying forms; it sets duration thresholds for construction and service projects to qualify as a permanent establishment, excludes solely preparatory or auxiliary activities from being a permanent establishment, treats dependent agents who habitually conclude contracts or secure orders predominantly for the enterprise as creating a permanent establishment, exempts agents of independent status acting in the ordinary course of business, and provides that mere control or affiliation between resident companies does not alone create a permanent establishment.

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