TaxTMI Login
Just a moment...
Press 'Enter' to add multiple search terms. Rules for Better Search
of 
of 
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of of 
All Acts & Rules
of of All Acts & Rules
Note
Bookmark
Share
Don't have an account? Register Here
of <h1>Understanding 'Permanent Establishment': Key Criteria and Exceptions for Business Activity Locations Under Agreement</h1> The term 'permanent establishment' in this agreement refers to a fixed place of business where an enterprise's activities are conducted, either wholly or partly. It includes places like management offices, branches, factories, workshops, and sites for resource extraction. Construction projects lasting over nine months, or service activities exceeding 90 days, also qualify. Exceptions include facilities used solely for storage, display, or auxiliary activities. An enterprise is considered to have a permanent establishment if a person in a contracting state habitually concludes contracts or maintains stock for the enterprise. Insurance enterprises collecting premiums or insuring risks also qualify, except through independent agents. Control by or of another company does not automatically establish a permanent establishment.
TaxTMI 
