Permanent establishment: fixed place or dependent agent activity triggers tax nexus under the DTAA framework.

Permanent establishment is a fixed place of business through which an enterprise's business is wholly or partly carried on, exemplified by management places, branches, offices, factories, workshops, sales outlets, warehouses providing storage for others, agricultural or resource extraction sites. Construction, installation or assembly projects and furnishing of services by personnel give rise to a permanent establishment only if they exceed the treaty's temporal thresholds. Exclusions cover preparatory or auxiliary activities including storage, display, stock maintenance, purchasing, information collection, and combinations thereof. Dependent agents with contracting authority, stock for delivery, or who habitually secure orders create a permanent establishment, while independent agents acting in the ordinary course do not. Insurance enterprises collecting premiums or insuring risks through non independent persons are treated as having a permanent establishment, excluding reinsurance. Control or affiliation alone does not constitute a permanent establishment.

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