Permanent establishment rules set fixed place and agency thresholds determining when cross border business creates taxable nexus.

The Article defines permanent establishment as a fixed place of business through which an enterprise conducts business and lists typical forms (management, branch, office, factory, workshop, sales outlet, warehouse, agricultural and extraction sites). It treats construction sites, installation or assembly projects and supervisory activities, extended service furnishing through personnel, and offshore exploration or exploitation as creating a permanent establishment when they exceed specified aggregate durations. Exclusions cover solely preparatory or auxiliary activities and independent agents acting in the ordinary course of business, while dependent agent activities that habitually conclude contracts, maintain stock for delivery, or secure orders for the enterprise give rise to a permanent establishment.

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