Permanent establishment definition determines taxable presence where a fixed place or dependent agent carries on business activities. A permanent establishment arises from a fixed place of business where an enterprise carries on activities, including management offices, branches, factories, warehouses, resource extraction sites, and building or installation projects meeting duration or charge thresholds. Preparatory or auxiliary activities, storage or display, stock maintenance for processing, purchasing, information collection, advertising, and ordinary independent agents do not constitute a permanent establishment, unless other fixed places exist or an agent acts almost exclusively for the enterprise; corporate control alone is insufficient to create one.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Permanent establishment definition determines taxable presence where a fixed place or dependent agent carries on business activities.
A permanent establishment arises from a fixed place of business where an enterprise carries on activities, including management offices, branches, factories, warehouses, resource extraction sites, and building or installation projects meeting duration or charge thresholds. Preparatory or auxiliary activities, storage or display, stock maintenance for processing, purchasing, information collection, advertising, and ordinary independent agents do not constitute a permanent establishment, unless other fixed places exist or an agent acts almost exclusively for the enterprise; corporate control alone is insufficient to create one.
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