Permanent establishment definition clarifies when fixed places or agent activities create taxable presence abroad. Permanent establishment arises from a fixed place of business or from persons acting on behalf of an enterprise where those persons habitually conclude contracts, maintain stock for regular delivery, or habitually secure orders; construction sites and prolonged service provision projects also constitute permanent establishments if they exceed the relevant duration thresholds; purely preparatory or auxiliary activities and truly independent agents acting in the ordinary course of business are excluded.
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 clarifies when fixed places or agent activities create taxable presence abroad.
Permanent establishment arises from a fixed place of business or from persons acting on behalf of an enterprise where those persons habitually conclude contracts, maintain stock for regular delivery, or habitually secure orders; construction sites and prolonged service provision projects also constitute permanent establishments if they exceed the relevant duration thresholds; purely preparatory or auxiliary activities and truly independent agents acting in the ordinary course of business are excluded.
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