Permanent establishment definition: fixed place or dependent agent can create taxable presence and obligations under a cross-border tax treaty. The permanent establishment rule attributes taxable presence to an enterprise that operates through a fixed place of business-such as management offices, branches, factories, warehouses for third party storage, agricultural or extraction sites-or through a dependent agent who habitually concludes contracts, maintains a stock for delivery, or secures orders principally for the enterprise. Exceptions cover activities of a preparatory or auxiliary character and independent agents acting in the ordinary course of business; insurance premium collection or risk assurance via non independent persons also constitutes a permanent establishment.
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: fixed place or dependent agent can create taxable presence and obligations under a cross-border tax treaty.
The permanent establishment rule attributes taxable presence to an enterprise that operates through a fixed place of business-such as management offices, branches, factories, warehouses for third party storage, agricultural or extraction sites-or through a dependent agent who habitually concludes contracts, maintains a stock for delivery, or secures orders principally for the enterprise. Exceptions cover activities of a preparatory or auxiliary character and independent agents acting in the ordinary course of business; insurance premium collection or risk assurance via non independent persons also constitutes a permanent establishment.
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