Permanent establishment: fixed place or dependent agent activities can create taxable presence under a tax treaty, with exceptions. Permanent establishment is a fixed place of business through which an enterprise's business is wholly or partly carried on and includes management offices, branches, factories, workshops, sales outlets, warehouses for storage services, agricultural sites and sites of natural resource extraction. Construction or installation projects and furnished services by personnel constitute a permanent establishment when they exceed specified duration thresholds. Exclusions cover mere storage, display, stock maintenance for processing, purchasing or preparatory or auxiliary activities. Dependent agents with contract authority, stock for delivery, or who secure orders can create a permanent establishment, while independent agents acting in the ordinary course generally do not.