Permanent establishment rules expand to cover construction, service and agent activities with MLI anti avoidance modifications.

The Agreement defines permanent establishment as a fixed place of business with enumerated examples and treats construction, installation, assembly and supervisory projects as PEs subject to MLI timing and aggregation rules. Service and offshore activities can constitute a PE where personnel furnish services or exploit seabed resources beyond specified aggregation periods. Specific activity exemptions exist for preparatory or auxiliary functions but are subject to anti avoidance modifications under the MLI. Agent provisions deem enterprises to have a PE where persons habitually conclude contracts, maintain stock for deliveries, or secure orders, while independent agent protection is lost if the agent acts almost exclusively for the enterprise or closely related entities.

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