Permanent establishment: fixed place or dependent agent activity can create taxable presence under the treaty with MLI safeguards. Permanent establishment is a fixed place of business through which an enterprise carries on business, with examples including management, branches, offices, factories, extraction sites and warehouses; construction or assembly sites and related supervisory activities form a permanent establishment when the convention's duration threshold is exceeded, subject to the MLI's aggregation of related periods and related enterprises' activities. Activity exemptions exist for preparatory or auxiliary functions, but the MLI prevents artificial avoidance by treating combined or related activities that are not preparatory or auxiliary as creating a permanent establishment. Agency and insurance rules further specify when a non independent agent or insurance collection creates a permanent establishment.