Permanent establishment: fixed place and dependent agent activities create tax nexus under the DTAA provisions.

The treaty defines permanent establishment as a fixed place of business, listing typical examples and imposing temporal tests: construction or project sites exceed the threshold only when lasting more than nine months, and service provision through personnel creates a permanent establishment when activities aggregate beyond six months in a twelve month period. The Article also excludes preparatory or auxiliary activities and certain storage, display and purchasing functions, and deems dependent agents with authority to conclude contracts, maintain delivery stock, or habitually secure orders to create a permanent establishment, while independent agents acting in the ordinary course do not.

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