Permanent establishment: fixed place or dependent agent presence may create taxable nexus for cross-border enterprises. Permanent establishment is a fixed place of business where an enterprise's business is wholly or partly carried on, expressly including management offices, branches, factories, workshops, warehouses, extraction sites and construction or assembly projects beyond a specified duration. Exclusions cover places used solely for storage, display, stockholding for processing, purchasing, information gathering, advertising or other preparatory or auxiliary activities. An enterprise is also deemed to have a permanent establishment when a non-independent agent habitually concludes contracts, maintains delivery stocks, or secures orders on its behalf, while independent agents acting in the ordinary course do not create such a nexus, and mere corporate control between residents is insufficient.