Permanent establishment rules define when a foreign business presence creates taxable nexus under treaty provisions for cross-border taxation.

Permanent establishment is a fixed place of business through which an enterprise's business is wholly or partly carried on, including specified examples and construction or installation projects exceeding the Article's duration threshold; dependent agents who habitually conclude contracts, maintain stock for regular delivery, secure orders principally for the enterprise, or manufacture/process goods create a permanent establishment, while preparatory or auxiliary activities and independent agents acting in the ordinary course of business do not, subject to exceptions and amended thresholds set out in the notification and protocol.

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