Permanent establishment rules define when a fixed place or personnel create taxable presence and treaty tax obligations. The Article defines permanent establishment as a fixed place of business and lists typical examples; it creates PE by prolonged construction, installation or drilling projects and by sustained furnishing of services through personnel. It excludes purely preparatory or auxiliary activities and certain storage, display or purchasing functions, and treats dependent agents, independent agents and insurance enterprises differently for PE attribution.
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 rules define when a fixed place or personnel create taxable presence and treaty tax obligations.
The Article defines permanent establishment as a fixed place of business and lists typical examples; it creates PE by prolonged construction, installation or drilling projects and by sustained furnishing of services through personnel. It excludes purely preparatory or auxiliary activities and certain storage, display or purchasing functions, and treats dependent agents, independent agents and insurance enterprises differently for PE attribution.
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