Permanent establishment defines when a fixed place or dependent agent creates tax presence and when activities remain preparatory.

Permanent establishment is a fixed place of business through which an enterprise's business is wholly or partly carried on, including places of management, branches, offices, factories, workshops, sales outlets, farms and extraction sites. Construction and service provision rules treat time-bound projects and continuing service activities as creating a permanent establishment only when they exceed specified durations. Exclusions apply to facilities used solely for storage, display, occasional delivery, stock maintenance for processing, purchasing or information collection, and activities of a preparatory or auxiliary character. Agency rules deem an enterprise to have a permanent establishment where a dependent representative habitually concludes contracts, maintains delivery stock, or secures orders; independent agents acting in the ordinary course do not create a permanent establishment.

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