Permanent establishment rules clarify fixed-place and agency thresholds, with MLI limits on activity exemptions and commissionaire arrangements. Permanent establishment is a fixed place of business through which an enterprise's business is carried on, with specified examples and a time-based rule for construction or installation projects. Preparatory or auxiliary activities and certain storage, display, purchasing or information-collection uses are excluded, but the MLI narrows those exemptions where combined activities are not preparatory or auxiliary or where the same or closely related enterprises carry on complementary activities at the same or another place. Agency and commissionaire provisions treat dependent agents who habitually conclude contracts or act almost exclusively for related enterprises as creating a permanent establishment.
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 rules clarify fixed-place and agency thresholds, with MLI limits on activity exemptions and commissionaire arrangements.
Permanent establishment is a fixed place of business through which an enterprise's business is carried on, with specified examples and a time-based rule for construction or installation projects. Preparatory or auxiliary activities and certain storage, display, purchasing or information-collection uses are excluded, but the MLI narrows those exemptions where combined activities are not preparatory or auxiliary or where the same or closely related enterprises carry on complementary activities at the same or another place. Agency and commissionaire provisions treat dependent agents who habitually conclude contracts or act almost exclusively for related enterprises as creating a permanent establishment.
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