Permanent establishment: fixed place or dependent agent activities create taxable presence under DTAA.

The Article defines permanent establishment as a fixed place of business or specified activities through which an enterprise carries on business, lists typical forms (place of management, branch, office, factory, workshop, sales outlet, warehouse, extraction sites), treats installations and equipment for natural-resource exploration or exploitation as PE, and converts certain building, construction, service-provision and resource-exploration activities into a PE when they exceed stated aggregate periods. It excludes preparatory or auxiliary activities unless combined or complementary activities with the same or closely related enterprises negate that character, and it treats dependent agents and certain insurance activities as creating a PE, with an independent agent exception and a definition of "closely related."

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