Permanent establishment rules: fixed place and agency activities can create tax nexus, with construction and service thresholds applying.

The Article defines permanent establishment as a fixed place of business carrying on enterprise activities and lists illustrative forms (management place, branch, office, factory, workshop, sales outlet, warehouse for others, agricultural sites, and resource extraction sites). It treats construction and installation projects and the furnishing of services through personnel as creating a permanent establishment where they exceed specified durations, while excluding solely preparatory or auxiliary fixed places. Agency provisions deem an enterprise to have a permanent establishment when a person habitually concludes contracts, maintains delivery stock, or secures orders for the enterprise, subject to an independent agent exception; insurance collection by non-independent agents also creates a nexus.

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