Permanent establishment: taxable presence arises from a fixed place of business or dependent agent activities creating PE. A business is deemed to have a permanent establishment where it conducts activities through a fixed place of business-examples include management places, branches, offices, factories, workshops, warehouses, farms, sales outlets, installations for natural resource operations, and long-term construction or assembly sites. Exclusions apply for solely preparatory or auxiliary activities (storage, display, stock maintenance, purchasing, or information collection) unless combined with other fixed places used for non-preparatory purposes. Dependent agents with authority to conclude contracts or maintaining delivery stocks can create a permanent establishment, while independent agents acting in the ordinary course generally do not. Special rules apply to mineral extraction services and insurance premium collection through non-independent agents.